Every year, around the end of December, taxpayers gear up to file their annual GST returns. For most, it has become a routine compliance task – open the portal, copy-paste from GSTR-3B, tick some boxes, and move on. But this year, that “autopilot” approach could land you in trouble.
For FY 2024-25, the GST annual return in Form GSTR-9 has undergone some significant changes. Reporting has become far more detailed, and several new FAQs and clarifications have been issued specifically for this year. In short, this is not just another year-end ritual.
As things stand today, the due date for filing GSTR-9 (and GSTR-9C, wherever applicable) remains 31st December 2025.
Who Needs to File
Form GSTR-9 is the annual summary return for all regular taxpayers. It brings together details you’ve already reported in GSTR-1 and GSTR-3B – your outward supplies, inward supplies, tax paid, and ITC availed or reversed – and consolidates them for the entire financial year. For FY 2024-25:
Mandatory filing if your aggregate turnover exceeds Rs 2 crore.
Exemption continues for those with turnover up to Rs 2 crore (as per Notification No. 15/2025-CT).
GSTR-9C, the reconciliation statement (often referred to as the “GST audit” form), applies if turnover exceeds Rs 5 crore.
The annual return can be filed only once all your relevant GSTR-1 and GSTR-3B for the year are in place.
While GSTR-9 may look like a summary form, in reality, it plays three very crucial roles:
1. Year-End Regulatory Closure
This is the department’s main reconciliation document. Any mismatch between your books, GSTR-1, GSTR-3B, and GSTR-9 is a red flag for possible audit or scrutiny.
2. ITC Hygiene Check
With ITC now being almost fully system-driven (thanks to GSTR-2B and the new Invoice Management System), the annual return forces you to document every bit of credit – availed, reversed, or carried forward. Even ITC claimed late, pertaining to earlier years, now needs to be reported distinctly.
3. Risk Identification
If your tax payable as per books does not match your GSTR-3B, GSTR-9 becomes the first document the department will rely upon to identify underpayment. Additional liability, if any, can be voluntarily paid through DRC-03 – now with greater ease for ITC-based payments.
The late fee for delay in filing remains punitive: Rs 200 per day (Rs 100 CGST + Rs 100 SGST), capped at 0.5% of turnover in the State/UT (0.25% + 0.25%). And remember – GSTR-9 or 9C cannot be revised once filed. So, an error or omission now can only be fixed through next year’s working or during audit proceedings.
FY 2024-25 brings one of the most significant overhauls to the annual return format since GST began.
1. New Table 6A1 for Prior-Year ITC
This new row captures ITC of FY 2023-24 that has been claimed in FY 2024-25. It brings clarity to cross-year credits and avoids disputes around “late availment”.
2. Reorganised Reversal & Reclaim Reporting
Temporary ITC reversals under Rules 37 and 37A (for example, for non-payment to vendors within 180 days) and their later reclaims are now to be reported distinctly, so that such credits do not get counted twice.
3. Fresh Clarifications on Spillover & RCM
New FAQs clarify that: RCM liabilities of FY 2024-25, paid in FY 2025-26, must be shown in FY 2025-26’s return.
ITC of FY 2023-24 claimed in FY 2024-25 goes into Table 6A1, while reversals of 2023-24 ITC made in 2024-25 do not figure in this year’s GSTR-9 at all.
The clear trend is that cross-year movements are now being officially tracked, not left to working papers and spreadsheets.
A practical roadmap for this year’s filing would be to start with a clean base. Before even opening GSTR-9, ensure that all your monthly or quarterly GSTR-1 and 3B filings are fully reconciled.
Identify invoices where supply, payment, and ITC claim years differ. These will influence your Table 6A1 and next year’s disclosures. Practitioners often wait until early December before final reconciliation – by then, most vendors have uploaded pending invoices and Table 8A data has settled.
Wherever there is a grey area – be it ITC eligibility or disclosure placement – record your reasoning internally. A short note today can save you hours in an audit later. If done methodically, the annual return does not have to be the stressful year-end exercise it is made out to be. In fact, it is an excellent self-review tool to gauge how healthy your GST processes really are.
(The writer, a Fellow Chartered Accountant (FCA), specialising in Goods, Services tax, Transfer Pricing and Income tax, is the co-author of the book ‘Comedium of Industrial Policy for MSMEs in Goa’ released by ICAI)
