Guide to Master GSTR-9 and GSTR-9C for F.Y. 2024-25

As a result of the introduction of the Goods and Services Tax (GST) regime in India, every eligible business is required to file an annual return (GSTR-9) and a reconciliation statement (GSTR-9C). The deadline for filing both of these returns is December 31st, 2025.

Therefore businesses must be prepared to meet these requirements after the end of the Financial Year (F.Y.) 2024-2025. This article discusses the key provisions that govern the compliance obligations of GSTR-9 and GSTR-9C.

Filing Requirements

I. GSTR-9 (Annual Return): The annual return for registered taxpayers is issued in the form of GSTR-9. All businesses with an aggregate turnover of over two crores in the year are required to file this return. GSTR-9 consolidates all of the taxable, exempt and export sales made by a taxpayer in that financial year on a single Permanent Account Number (PAN).

Complete Supreme Court Judgment on GST from 2017 to 2024 with Free E-Book Access, Click here

II. GSTR-9C (Reconciling Statement): Taxpayers that have an annual turnover of more than five crores must also submit GSTR-9C. This is an additional reunifying self-certified document that has to be drawn up by the taxpayer to establish that their books and records are consistent with those made by the taxpayer in their GST returns during the year.

Reporting Outward Supplies

Documentation of transactions related to the sale of goods and the collection of GST is addressed in the new guidelines:

• Table 4, specific requirements relate to taxable supplies, advances received and inward RCM. In addition, there is a new section on electronic commerce operators, referred to as Table 4A to support the emergence of new business Models for online selling.
• Table 5 provides information on zero-rated supplies, categories which are exempt from GST, supplies that are unregistered and non-GST transactions. There is also a new section, Table 5CF specifically for e-commerce suppliers.

• Tables 10 & 11 support the adjustment of "spillover" transactions, allowing taxpayers that report a part of the 2024-25 financial year in their GSTR's for April 2025 or October 2025 to make that declaration.

It is pertinent to remember that all information relating to the transactions only concerning the F.Y. 2024-25 must be declared.

Complete Supreme Court Judgment on GST from 2017 to 2024 with Free E-Book Access, Click here

Input Tax Credit (ITC) Provision

1. Alterations to ITC - A change is made in the reporting requirements outlined in the legislation, the requirement for tables 6 and 7 is to provide only information about the F.Y. 2024-25. There will not be any historical data reported on the returns for previous fiscal years in these tables.

2. Table 6A - Initial Data Population: This table will automatically have its data filled through GSTR-3B filings during the F.Y. 2024-25, helping taxpayers enter their data more easily.

3. Table 6A1 - Exclusion Mechanism: Table 6A1 will allow taxpayers to exclude, at their request, input tax credits that were claimed in the F.Y. 2023-24 and subsequently claimed in the F.Y. 2024-25, in order to prevent duplicate claims for input tax credits.

4. Table 6H - Special Re-claim Category: Table 6H is designed to fit the scenario where a taxpayer initially claims input tax credits, reverses the input tax credits, and reclaims those same input tax credits in the F.Y. 2024-25 under rule 37 and rule 37A of the statute.

5. Table 8B - Accuracy Maintained by De-linking: Table 8B will receive automatic population only from data in table 6B, allowing this table to operate separately from table 6H to avoid discrepancies in the filing of returns.
6. Table 8C - Missed Credits: Taxpayers will only be allowed to use this table for missed claimed ITCs that occurred between April 2025 and October 2025. There is an explicit prohibition against reporting reclaimed credits in this table.

Categories of Reclaimed Input Tax Credit

The framework distinguishes between the following two categories of input tax credit transactions:

Case 1: Reclaimed ITC transactions that are not falling under Rule 37 or Rule 37A will be treated like prior year ITCs and will therefore be excluded from the reporting through Table 6A1.

Case 2: Reclaimed ITCs that fall under the Rule 37 or Rule 37A requirements will be considered as current year ITC credit and must be disclosed in the reporting Table 6H.

Reporting Optional Tables

The new framework also has optional tables available to assist taxpayers in FY 18/19.

1. Table 15 - Demands & Refunds of Supplies
2. Table 16 - Depiction of Composition Scheme
3. Table 18 - Summary of Inward supplies based on HSN classification system

Final compliance considerations

i. Addressing differences - Taxpayers for mismatched reported values should conduct a detailed review of the underlying causes. For unresolvable discrepancies shown in GSTR-9C, the GST system offers fields designated in Tables 12-14. Identifying and correcting discrepancies promptly can mitigate risk if there is future scrutiny.

ii. Past errors -The existing guidance assumes that these new guidelines will create unintentional differences between past GSTR-9 filings and GSTR-3B Data. Taxpayers that find themselves in this predicament are encouraged to document the situation properly.

iii. Final opportunity for corrections - GSTR-9 serves as the last chance for taxpayers to correct errors identified in their GSTR-1 and GSTR-3B submitted during the F.Y. 2024-25. Taxpayers should take advantage of completing their GSTR-9 filing to ensure full compliance and accuracy.

The GSTR-9 and GSTR-9C requirements for F.Y. 2024-25 have undergone several changes that are intended to simplify and improve accuracy and reduce taxpayer compliance burden. Taxpayers need to understand the new table layout, including the specialized provisions for reclaims and exceptions on ITC. Businesses should make preparations now before the cutoff date of December 31, 2025 to allow for adequate reconciliation, verification, and timely filing of these two important annual filings.

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