Introduce Amnesty Scheme For GSTR‐9C Filings For FYs Prior To 2022‐23: A.P. Tax Bar Association Writes To FM Nirmala Sitharaman

The A.P. Tax Bar Association while giving representation to Union Finance Minister Nirmala Sitharaman expressed the need for introduction of an amnesty scheme for GSTR‐9C filings for the Financial Years prior to 2022‐23.

The Bar Association stated that there is a need for an amnesty scheme for GSTR‐9C filings for the Financial Years prior to 2022‐23 as many taxpayers and professionals faced significant challenges in complying with the deadlines of the GSTR‐9C due to the complexity of the GST framework.

The Association suggested the applicability of late fee for GSTR‐9C as notified on 23‐01‐2025 vide Notification No. 08/2025‐CT and stated that the GSTR‐9C is a reconciliation statement but not an annual return. It falls outside the purview of section 47(2) and section 35(5) of the GST Act 2017, hence the late fee provision for GSTR‐9C as mentioned in the notification be reconsidered or clarified. 

It was stated in the representation that GSTR‐9C is not an annual return and it is only a reconciliation statement which has to be filed along with the annual return in Form ‐9 and it is not included in Section 47(2) as also section 35(5) for the financial years 2019‐20 and also the wording of complete annual return may be clarified with the different / distinct provisions of section 44 and 35(5).

“We humbly submit that GSTR‐9C is only a reconciliation statement to be filed along with the annual return i.e. GSTR‐9 and the question of levy of any late fee on GSTR‐9C would not arise,” writes A.P. Tax Bar Association while requesting to delete the GSTR‐9C late fee payment from the notification or issue a clarificatory notification to this effect.

Read More: Advisory On Alternate Mechanisms And Business Continuity Plans Available For E-Invoice, E-Waybill Systems: GSTN

Representation Details

Date: 24/01/2025

Mariya Paliwala
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