The Central Board of Indirect Taxes and Customs (CBIC) has introduced significant updates to the GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) forms for FY 2024–25, aimed at improving accuracy, automation, and compliance efficiency. These changes align with ongoing GST rationalisation efforts and address long-standing challenges faced by taxpayers and professionals during annual return filing.
Below is a detailed breakdown of the key modifications and their practical impact.
Availability of GSTR-9/9C
The GST portal will enable the filing of GSTR-9 and GSTR-9C only after all monthly or quarterly GSTR-1 and GSTR-3B returns for FY 2024–25 are filed.
No pending return means no GSTR-9 activation.
This move enforces return discipline and ensures data consistency across return forms before annual reconciliation begins.
Auto-Population Enhancements
Auto-population logic has undergone substantial refinement to improve accuracy in ITC reconciliation:
- Table 8A now includes invoices of FY 2024–25 appearing in GSTR-2B up to October 2025.
- It excludes invoices of FY 2023–24 that appeared between April and October 2024.
- GSTR-1A amendments are now incorporated in Tables 4 and 5, ensuring a more holistic reflection of outward supply corrections.
Introduction of New Table 6A(1)
A new sub-table, 6A(1), has been added to capture Input Tax Credit (ITC) of the preceding financial year (2023–24) claimed in the current year (2024–25).
This feature eliminates earlier mismatches reflected in Table 6J and provides better visibility into cross-year ITC claims.
Streamlined ITC Claim–Reverse–Reclaim Reporting
GSTN has simplified the reporting flow for ITC adjustments within the same financial year:
- Claim ITC: Table 6B
- Reverse ITC: Tables 7A–7H
- Reclaim ITC: Table 6H
This structured segregation results in cleaner and traceable ITC reporting, easing audit and reconciliation.
Cross-Year ITC Reclaim (Rules 37 & 37A)
Where ITC is reclaimed under Rule 37 (non-payment to vendor) or Rule 37A (GSTR-1 vs 3B mismatch corrections), the credit will now be treated as ITC of the year of reclaim and must be reported only in Table 6H.
This prevents duplication and ensures that reclaims are accurately tied to the financial year in which they occur.
Missed ITC Claimed in Subsequent Year
If any ITC related to FY 2024–25 is claimed in FY 2025–26 (within the statutory time limit under Section 16(4)), it must be:
- Reported in Table 8C and Table 13,
- Not shown in Table 6H.
This ensures clarity on ITC availed after the close of the financial year but within permissible timelines.
Reporting IGST on Imports Claimed in the Next FY
A new Table 8H(1) has been introduced to capture IGST paid on imports where credit is availed in the next financial year.
Taxpayers must also report the same in Table 13 of FY 2024–25.
This change provides traceability for import-related ITC timing differences.
Simplified Table Linkages
Linkages between input tax tables have been redesigned to avoid recurring mismatches:
- Table 6H is now delinked from Table 8B.
- Table 8B will auto-populate only from Table 6B, ensuring consistency.
This simplification addresses earlier issues in Table 8D mismatches, reducing reconciliation errors.
Late Fee Auto-Calculation (Circular No. 246/03/2025-GST)
Late fees under Section 47(2) will now be auto-calculated for both GSTR-9 and GSTR-9C filings.
Notably:
- Delay in filing GSTR-9C will be calculated from the later of the due date of GSTR-9 or the actual filing date of GSTR-9, ensuring equitable computation.
This automation reduces manual calculation errors and ensures uniformity across taxpayers.
Other Noteworthy Updates
- Table 6M (relating to ITC under Forms ITC-01/02/02A) remains unchanged.
- New Excel utilities are now available to download Table 8A data and HSN summary (Table 17) for better offline analysis.
- The concessional 65% tax payment option has been removed, aligning with the government’s broader rationalisation strategy.
Key Takeaways for Tax Professionals
File all GSTR-1 and GSTR-3B returns promptly to unlock GSTR-9 access.
Leverage the new Table 6A(1) and Table 8H(1) to ensure transparent cross-year ITC tracking.
Report ITC reclaims under Rule 37 or 37A strictly in the year of reclaim.
Use the new Excel reconciliation tools to verify Table 8A and HSN summary accuracy.
Review late fee implications carefully under the new automated computation system.
Conclusion
The FY 2024–25 updates to GSTR-9 and 9C mark a decisive step toward greater automation and precision in GST annual compliance. While the structural changes may initially require familiarisation, they ultimately simplify reconciliation, reduce mismatches, and improve audit transparency.
Tax professionals are advised to plan early reconciliations, review vendor ITC data thoroughly, and use the new system features to ensure a smooth and error-free filing season.
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