As per provisions of Sec.35(5) every registered person whose turnover during a financial year exceeds the prescribed limit shall get his accounts Audited by a chartered accountant or a cost accountant and shall submit a copy of the Audited annual accounts, the reconciliation statement under sub-section (2) of section 44 and such other documents in such form and manner as may be prescribed.

As per Rule 80 of CGST Rules, every registered person whose aggregate turnover (taxable as well as exempted turnover) during a Financial year (i.e. April to March) exceeds two crore rupees shall get his accounts Audited as specified under sub-section (5) of section 35 and he shall furnish a copy of Audited annual accounts and a reconciliation statement, duly certified, in FORM GSTR-9C, electronically through the common portal either directly or through a Facilitation Centre notified by the Commissioner.

As per clarification issued by CBIC dated 03.07.2019, turnover of VAT period should not be included for determining eligibility of filing of reconciliation statement (GSTR-9C).

As per format of GSTR-9C, there is no requirement to upload the financial statement of a particular period i.e. July 2017 to March 2018, thus taxpayer can upload the financial statement of whole financial year (01.04.2017 to 31.03.2018).

Internal Auditor can’t undertake Goods and Service Tax (GST) Audit of same Entity due to Role Conflict.

Section 35(5) is not application on every 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.