Annual return, reconciliation statement and the LUT that lets exporters ship without paying IGST.
The annual return is not a summary of the monthly returns — it is the reconciliation between what you told the department during the year, what your books say, and what your customers claimed. It is the document a departmental audit starts from, and errors in it are what generate scrutiny notices eighteen months later. We prepare GSTR-9 and, where applicable, GSTR-9C, from the books rather than by copying the auto-populated figures.
Who files what
Aggregate turnover in the financial year
GSTR-9
GSTR-9C
Up to ₹2 crore
Optional
Not required
Above ₹2 crore up to ₹5 crore
Mandatory
Not required
Above ₹5 crore
Mandatory
Mandatory, self-certified
Turnover is aggregated PAN-wide across India, but the return is filed GSTIN-wise. A business with registrations in Tamil Nadu and Karnataka crossing ₹5 crore in total files GSTR-9C for both. Composition dealers file GSTR-9A, and e-commerce operators collecting TCS file GSTR-9B.
Due date: 31 December following the end of the financial year. Late fee accrues per day of delay, subject to a cap linked to turnover.
The annual return is your last chance to fix the year. Amendments to a financial year's invoices, and input tax credit for that year, can only be made up to 30 November of the following financial year or the date of filing the annual return, whichever is earlier. Filing GSTR-9 early closes that door. Reconcile first, correct in the monthly returns, then file the annual return.
Where reconciliations break
Credit notes issued after year end relating to supplies of the year, reported in the next year's GSTR-1 but booked in this year's accounts
Input tax credit reversals under Rule 42 and 43 for exempt supplies, and the Rule 37 reversal where a supplier was not paid within 180 days
Credit claimed in one year but appearing in 2B of another — the two-year table in GSTR-9 exists precisely for this and is filled wrongly more often than not
Reverse charge liability on freight, legal fees, director remuneration and imports of service, paid but with the corresponding credit not taken, or vice versa
Turnover per books versus turnover per returns — discounts, scrap sales, other income, foreign exchange gain and the treatment of schedule I transactions between related persons
Stock transfers between your own GSTINs in different states, which are taxable supplies even though nothing is sold
Letter of Undertaking for exporters
Exports and supplies to a Special Economic Zone are zero-rated. There are two routes: pay IGST and claim refund, or file a Letter of Undertaking in Form RFD-11 and export without payment of tax. For most Chennai exporters the LUT is materially better — it avoids blocking working capital in a refund cycle that can run for months.
The LUT is filed on the GST portal for each financial year, before the first export of that year
It is valid for one financial year and must be renewed — typically in April
Available to any registered exporter who has not been prosecuted for tax evasion exceeding the prescribed threshold
Exporting without a valid LUT means IGST becomes payable on the export invoice, and the refund route is then the only way to recover it
If you are also claiming refunds of accumulated credit on zero-rated supplies, the refund application in RFD-01 has to align with the LUT position and the shipping bill data on ICEGATE. We handle these together with IEC compliance for exporters.
What we do
Books-to-return reconciliation for the full year, GSTIN by GSTIN, with a working paper you keep.
Corrections routed through the current period's GSTR-1 and 3B where the window is still open.
GSTR-9 prepared from the reconciled figures, with each table traced to a working.
GSTR-9C reconciliation statement prepared and self-certified, with the unreconciled differences explained rather than forced.
Filed and archived with the workings, so that a scrutiny notice two years later is answered from a file rather than reconstructed.
Frequently asked questions
It is optional, and for a clean small business it is usually not worth the cost. It is worth filing voluntarily in two situations: where you want the year formally closed because a sale or fundraise is coming, and where the reconciliation itself throws up credit you can still claim. Otherwise the exemption is there to be used.
No. The annual return cannot be revised once filed, which is why the reconciliation has to be complete before submission. Errors discovered afterwards have to be dealt with through DRC-03 voluntary payment, or explained when the notice arrives.
Not since the change to self-certification. GSTR-9C is now self-certified by the taxpayer rather than audited and certified by a chartered accountant or cost accountant. The reconciliation work still has to be done properly, because the self-certification shifts responsibility onto the taxpayer rather than removing it.
File the LUT immediately; it operates for the financial year from the date of filing. For exports made before it, IGST is technically payable on those invoices with a refund claim available. In practice, filing the LUT and disclosing the position is far better than leaving a gap that surfaces during a refund scrutiny.