The Bombay Chartered Accountants Society (BCAS) has submitted a detailed follow-up representation to the Union Finance Minister, the Chairperson of the Central Board of Indirect Taxes and Customs (CBIC), the GST Council Secretariat, and senior GST authorities, urging an extension of the due date for filing Form GSTR-9 (Annual Return) and Form GSTR-9C (Reconciliation Statement) for the financial year 2024–25.
In its representation dated December 29, 2025, BCAS highlighted that despite sincere efforts by taxpayers and professionals to comply with the statutory deadline of December 31, 2025, a combination of regulatory changes, audit dependencies, and overlapping statutory obligations has made timely and accurate compliance extremely challenging.
Increased Granularity and Complexity in ITC Reporting
BCAS pointed out that recent amendments to Forms GSTR-9 and GSTR-9C, introduced through Notification No. 13/2025-CT dated September 17, 2025, have significantly enhanced the level of granularity required in Input Tax Credit (ITC) reporting. Taxpayers are now required to undertake extensive bifurcation of ITC earlier reported in consolidated tables of GSTR-3B into multiple new and highly detailed tables in GSTR-9 and GSTR-9C.
These changes require tracking of ITC across multiple financial years, including credits pertaining to FY 2023–24 impacting FY 2024–25, as well as ITC of FY 2024–25 that spills over into FY 2025–26. According to BCAS, this effectively mandates reconciliation of data across three different financial years to ensure accurate annual reporting, substantially increasing the compliance burden on businesses and professionals.
The representation also flagged a major shift in the auto-population logic of Table 8A of GSTR-9. From FY 2024–25 onwards, auto-population is aligned with the document date rather than the GSTR-2B period, adding further complexity to reconciliation exercises and requiring redesign of long-standing internal processes and reconciliation workbooks.
Dependence on Audited Financial Statements
BCAS emphasized that Form GSTR-9C is intrinsically dependent on the availability of audited annual financial statements. Since the due date for tax audits was extended to November 10, 2025, audited financial data became available only by mid-November in many cases. This has significantly compressed the effective time available for preparing and validating annual returns and reconciliation statements, making error-free compliance within the existing deadline operationally difficult.
Overlapping Statutory and Adjudication Deadlines
The representation further noted that November and December 2025 coincided with critical adjudication timelines under the CGST Act. The deadline for completion of adjudication proceedings under Section 73 for FY 2021–22 and Section 74 for FY 2018–19 also falls on December 31, 2025. As a result, taxpayers and professionals have been required to simultaneously manage responses to show cause notices, attend hearings, and complete annual GST compliances, leading to a severe procedural squeeze.
Formal Request for Extension
Considering the cumulative impact of enhanced reporting complexity, dependence on audited financials, and overlapping adjudication pressures, BCAS has formally requested a suitable extension of the due dates for filing GSTR-9 and GSTR-9C for FY 2024–25. The society submitted that such an extension would promote fair, accurate, and error-free compliance, and noted that similar concerns have been echoed by other professional bodies and trade associations across the country.
About BCAS
Established in 1949, the Bombay Chartered Accountants Society is one of India’s leading professional bodies for chartered accountants, with over 11,500 members nationwide. BCAS regularly engages with policymakers and tax authorities to suggest reforms and procedural improvements aimed at achieving efficient administration and taxpayer-friendly compliance systems
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