The question
1 answer
Practising chartered accountants at ERPCA · 3 Oct 2026
In short
GSTR-9 is required for both registrations; GSTR-9C is not.
The thresholds are on aggregate turnover across all GSTINs under the same PAN. The annual return in GSTR-9 is optional only for taxpayers up to ₹2 crore, so at ₹4.2 crore you must file one for each registration. The reconciliation statement in GSTR-9C is required only above ₹5 crore, so you are outside it this year. Both are due by 31 December 2026.
Late fee for turnover between ₹2 crore and ₹5 crore is ₹50 a day (₹25 CGST plus ₹25 SGST), capped at 0.04% of turnover in the state (0.02% under each Act), charged per registration.
What to prepare: GSTR-9 is largely auto-populated from your GSTR-1 and GSTR-3B for the year, but table 8 reconciles the ITC you claimed with GSTR-2B, and table 6 asks for a break-up of inputs, input services and capital goods that the monthly returns never asked for. Any ITC that belongs to FY 2025-26 but was missed can still be claimed, and any excess reversed, in the GSTR-3B for October 2026 (filed in November), which is the last return where FY 2025-26 adjustments are allowed.
Next step
Pull the GSTR-2B versus books reconciliation for both states now, settle the differences in the October return, and file GSTR-9 in early December rather than on the last day when the portal is slow.
General guidance on the facts given, not an engagement. Law as on the date of the answer.
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