GST Annual Return GSTR-9 and Reconciliation Statement GSTR - 9C: GSTN answers FAQs [Read FAQ Here]

The Goods and Services Tax Network (GSTN) has released a comprehensive set of FAQs addressing numerous practical and technical issues faced by taxpayers while filing the Annual Return (Form GSTR-9) and Reconciliation Statement (Form GSTR-9C) for the financial year 2024-25.

The clarifications cover new auto-population logic, treatment of Input Tax Credit (ITC) adjustments, differences between forms, and computation of late fees under Section 47(2) of the CGST Act.

When and How GSTR-9/9C Becomes Enabled

GSTR-9 and GSTR-9C for FY 2024-25 will be enabled automatically once all corresponding GSTR-1 and GSTR-3B returns for the financial year are filed. If any return remains pending, the annual return forms cannot be accessed. Auto-populated data for Tables 4, 5, 6, 8, and 9 will be drawn directly from filed returns and statements such as GSTR-1/1A/IFF, GSTR-2B, and GSTR-3B.

Auto-Population and Table-Wise Clarifications

Table 8A — will capture inward supply details from GSTR-2B for FY 2024-25, including invoices from April–October 2025, while excluding invoices from FY 2023-24 appearing in FY 2024-25 returns. GSTN has also introduced an “8A Excel Download” option for detailed invoice-wise review.

Differences may arise between the Excel and Online UI of Table 8A due to reverse charge corrections, amendments across financial years, or mismatched place-of-supply adjustments. GSTN confirmed that Table 8A (online) will be the correct reference for return filing.

Table 6A1 and 6A2 — New segregation has been introduced to separately identify ITC of preceding FY (2023-24) claimed in FY 2024-25 and to prevent double reporting. ITC claimed, reversed, and reclaimed in the same year must now be properly classified under Tables 6B, 7A–7H, and 6H, depending on the cause of reversal (Rule 37, 37A, or others).

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Reporting of ITC Across Financial Years

GSTN has clarified nuanced treatment for ITC adjustments across years:

• ITC claimed in FY 2024-25 but reclaimed in FY 2025-26 will depend on the reason for reclaim.
• If under Rule 37/37A, it will appear in Table 6H of the next year’s return.
• Otherwise, it is to be reported in Table 13 of FY 2024-25 and Table 6A1 of FY 2025-26.
• Table 8C will now only include missed ITC of FY 2024-25 claimed in GSTR-3B of FY 2025-26, not ITC that was claimed and reversed earlier.
• Imports reported in FY 2024-25 but ITC availed in FY 2025-26 should now be declared in the new Table 8H1, ensuring reconciliation under Table 8I shows nil difference.

Label and Functional Updates

GSTN has aligned various table labels with statutory instructions:

• Table 6M will now include ITC availed through ITC-01, 02, and 02A.
• Table 8B has been delinked from Table 6H to avoid mismatches in 8D.
• Concessional 65% rate checkbox has been removed from Tables 17 and 18.
• Tables 12 and 13 retain the same purpose — to capture ITC reversed or availed in the subsequent year.

Additionally, a new HSN Download Tool has been introduced, providing consolidated Table 12 data from GSTR-1/1A to facilitate completion of Table 17 in GSTR-9.

Late Fee Computation for GSTR-9C

Based on Circular No. 246/03/2025-GST dated 30 January 2025, late fees under Section 47(2) will now apply to both GSTR-9 and GSTR-9C. A new Table 17 – “Late Fee Payable and Paid” has been added in GSTR-9C. The fee is auto-calculated by the system from the due date of filing GSTR-9 till the actual filing date of GSTR-9C.

For example:

• If GSTR-9 is filed on 25 December 2025 (before the due date of 31 December) and GSTR-9C on 7 January 2026, no late fee applies to GSTR-9, but a 7-day fee will apply to GSTR-9C.
• If GSTR-9 is filed late, the system calculates late fee portions separately for both returns.

ITC Reclaimed Year

GSTN reaffirmed that ITC reclaimed under Rule 37/37A is treated as ITC of the year in which it is reclaimed, not of the original invoice year. Thus, it must be declared in Table 6H of that year’s return.

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