A GST reconciliation statement is a reconciliation between the details filed as per the GST annual return in form GSTR-9 and details are per audited financial statement.
The main objective of the GST reconciliation statement is to make sure that the turnover declared, taxes paid, refund claimed, and input tax credit availed are reconciled between the GST annual return and books of account.
The registered person, who is required to furnish GST annual return in the terms of the provisions of section 44 read with rule 80, has to furnish the annual return in FORM GSTR-9 along with a copy of the audited annual accounts and a reconciliation statement in FORM GSTR-9C.
Who should file a GST reconciliation statement in GSTR-9C?
Every registered person other than followings whose aggregate turnover during a financial year exceeds 5 crore rupees, shall furnish a self-certified reconciliation statement in Form GSTR-9C along with the annual return on or before the thirty-first day of December following the end of such financial year.
- an Input Service Distributor
- a person paying tax under section 51 or section 52
- a casual taxable person
- a non-resident taxable person
- any department of the Central Government or a State Government or a local authority, whose books of account are subject to audit by the Comptroller and Auditor-General of India, or an auditor appointed for auditing the accounts of local authorities under any law for the time being in force.
Aggregate turnover is the sum-total of turnover in a State/ UT of All GSTINs obtained under a PAN.
GST reconciliation statement in FORM GSTR 9C would be applicable for all registration under the same PAN once the aggregate turnover crosses the limit of Rs. 5 Crore.
Consequence of failure to submit the Annual Return and Reconciliation Statement
Late fee will be levied if a person fails to furnish the annual return in Form GSTR-9 by the due date. Here is a table showing the late fee to be charged based on the turnover of the taxpayer. The late fee is levied for furnishing the annual return beyond the prescribed time.
| Turnover limit | Minimum late fee | Maximum Late fee |
| For turnover up to Rs. 5 Crore | Rs. 25 for every dayUnder CGST plus Rs. 25 for every day under SGST during which the failure continues. | 0.02 % under CGST plus 0.02 % under SGST of histurnover in the State orUnion territory. |
| For turnover of Rs. 5 Crore to Rs. 20 Crore | Rs. 50 for every dayUnder CGST plus Rs. 50 for every day under SGST during which the failure continues. | 0.02 % under CGST plus 0.02 % under SGST of histurnover in the State orUnion territory. |
| For turnover above Rs. 20 Crore | Rs. 100 for every dayUnder CGST plus Rs. 100 for every day under SGST during which the failure continues. | 0.025 % under CGST plus 0.025 % under SGST of histurnover in the State orUnion territory. |
We do not have any specific penalty for not submitting a GST reconciliation statement. However, section 125 of the CGST Act may be applied where the taxpayer shall be subjected to a penalty of up to Rs. 25,000.
Section 125 deals with the general penalty which gets attracted where any person, who contravenes any of the provisions of this Act, or any rules made there under for which no penalty is separately provided.
