Important points to consider while filing GSTR-9 & 9C

The Annual Return is a comprehensive consolidation of all outward supplies, inward supplies, input tax credit, tax payments, liabilities, and adjustments made during the financial year.

Since due date to file Annual return (GSTR-9/9C) in GST for F.Y. 2024-25 is approaching, here are some significant changes brought by CBIC by way of issuing Notification No. 13/2025 (central tax) which are need to be considered while filing GSTR-9/9C.

The object of the structural changes is to make the Annual Return more comprehensive and detailed with insertion of few new Tables mostly related to Input tax credit. 

1. ITC Reporting (Part III – Table 6, 7, 8)

1.1 New ITC Sub-Tables Introduced

Table 6A1 – ITC of Previous FY Availed in Current FY which includes-

• ITC of preceding FY (2023-24) availed in GSTR-3B of April 2025 –October 2025 of the FY (2024-25) being reported

• But excludes ITC reclaimed under Rule 37 or 37A

• Includes ITC reclaimed in current FY for reversals other than Rule 37/37A

Previously, if you claimed last year’s ITC in the current year and it wasn’t captured in the previous year’s Table 8C or 13, there was no proper disclosure mechanism.

1.2 Table 6A2 – Net ITC of Current FY

Formula introduced:

Net ITC of the financial year =(A-A1)

1.3 Table 6B-

For FY 2024-25 onwards, in case of ITC availed, reversed and then reclaimed, ITC which was availed (for the first time) should be declared in this table. ITC which was reversed should be declared in the Table 7 and ITC that is reclaimed should only be declared in Table 6H.

1.4 Table 6J

For FY 2024-25 onwards, the difference between the total amount of net ITC of the financial year availed through FORM GSTR-3B as per Table 6A2 and input tax credit declared in row B to H shall be auto populated here. Ideally, this amount should be zero.

1.5 Table 6M

Separate reporting of ITC-02 in Table 6M. Wordings modified, can no longer be used as a residuary ITC cell

1.6 Table 7: Enhanced ITC Reversal Tracking 

A fully restructured Table 7.

New rows:

7A1 – Reversal under Rule 37A

7A2 – Reversal under Rule 38

Key Change: ITC reclaimed due to Rule 37 or 37A must be shown under Table 6H, not 6A1. This distinction is crucial for accurate reporting. 

Example- If any ITC of current FY 2024-25 was claimed and reversed in the FY 2024-25 but reclaimed (due to rule 37/37A) in the next FY 2025-26 then such ITC will be reported in GSTR 9 as under -

1. Original claim shall be reported in Table 6B of GSTR 9 for FY 2024-25

2. Reversal of same shall be reported in Table 7A (rule 37) or 7A1 (rule 37A) of GSTR 9 for FY 2024-25

3. Reclaim shall not to be reported in table 8C and 13 of GSTR 9 for FY 2024-25

4. Reclaim shall be reported in table 6H of GSTR 9 for FY 2025-26 (in GSTR 9 of next Year).

1.7 Table 8B

For FY 2024-25 onwards, the input tax credit as declared in Table 6B shall be auto populated in Table 8B.

Amount reported in the Table 6H will not be part of Table 8B.

ITC which is reclaimed by the recipient will not appearing in GSTR 2B again and hence it will not be auto populated in Table 8A. As, the ITC reclaimed is also not required to be reported in the Table 8C. Therefore, delinking of Table 6H with 8B will mitigate the possibility of causing difference in Table 8D of GSTR 9.

1.8 Newly inserted Table 8H1

IGST Paid on import of goods be reported in Table 8G and Amount of ITC Claimed in next FY to be reported in Table 8H1 and therefore the difference in the Table 8I will be NIL. Also, this ITC will be reported in the Table 13 of GSTR 9 of 24-25.

2. Table 9

Enhanced Tax Payment Reporting

Two New Columns Added:

1. Total Tax Paid: Sum of cash and all types of ITC used

2. Difference Between Tax Payable and Paid: Any remaining tax liability that must be paid through DRC-07 

This provides clearer visibility of tax payment status and outstanding liabilities.

3. Part V (Tables 10–14) – Transactions of Next FY

Table 10- From FY 2024-25 onwards, for Table 10, details of supplies or tax increased through invoices or debit note or upward amendment of the same pertaining to the financial year but furnished in FORM GSTR-1 or as amended in FORM GSTR-1A or furnished through invoice furnishing facility of April to October of the next financial year, filed upto 30th November of next financial year shall be declared in Table 10.

Table 11- From FY 2024-25 onwards, for Table 11, details of supplies or tax reduced through invoices or credit note pertaining to the financial year but furnished in FORM GSTR-1 or as amended in FORM GSTR-1A or furnished through invoice furnishing facility of April to October of the next financial year, filed upto 30th November of next financial year shall be declared in Table 11.

Table 12 & 13 are now mandatory – ITC of FY 24-25, claimed and reversed in GSTR 3B of FY 25-26 (before 30th Nov.)

Table 12- For FY 2024-25 onwards, aggregate value of reversed ITC of the financial year which has been reversed through the return filed in next financial year filed upto 30th November, shall be declared in Table 12 (This will not be part of Table 7)

Table 13- For FY 2024-25 onwards, details of ITC on supply of goods or services received pertaining to the financial year but ITC for the same was availed in return from April to October of next financial year filed upto 30th November, of next financial year shall be declared here. Table 4(A) of FORM GSTR-3B of April to October of next financial year may be used for filling up these details.

However, any ITC which was reversed in any of the financial years as per rule 37 or rule 37A but was reclaimed in next financial year, the details of such ITC reclaimed shall be furnished in the Table 6H of GSTR-9 to be filed for next financial year only. The same shall not to be reported in Table 13.

4. Table 17 (HSN Summary): New Download Utility

A new Excel utility is provided:

• “Download Table 12 of GSTR-1/1A HSN Details”

• Includes an additional sheet in the format of Table 17

Taxpayers can directly use this to report accurate HSN data in GSTR-9.

5. Payment of additional tax liability – Form GSTR 9 earlier mentioned to be paid in cash, now allows utilisation of input tax credit. Although, GST portal allowed credit utilization in line with GST law.

Major Changes in GSTR-9C

Taxpayers having turnover more than Rs. 5 crores are required to file GSTR 9C. Therefore, those persons between Rs. 2 crore & Rs. 5 crores need not file Form GSTR 9C but require filing GSTR 9.

1. Table 7D1 introduced – Supplies on which tax is to be paid by ECO as per s9(5) [Supplier to report], as it would not form part of taxable turnover.

2. Table 9K2 introduced - Supplies on which tax is to be paid by ECO as per s9(5) [ECO to report]

3. Table 5B – Turnover reconciliation – Unbilled Revenue at the beginning of the year can be merged and disclosed in table 5O.

4. Other Turnover reconciliations from table 5C to 5N – Must be disclosed separately and cannot be clubbed under Table 5O. Earlier, relaxation was available till FY 2021-22 as single disclosure in table 5O.

5. Table 12B & 12C – No more optional, mandated to disclose such ITC details from FY 2023-24 onwards.

6. Table 14 – Remains optional to fill expense wise ITC claim details (this may also be available from disclosure in clause 44 of Tax Audit Form 3CD).

7. Table-17- A new table Table 17 – “Late Fee Payable and Paid” has been added to GSTR-9C.

Apart from above points, taxpayer should also refer FAQs dated 16.10.2025 issued by GST portal on GSTR -9/9C for FY 2024-25 for assisting the taxpayer in filing GSTR-9/9C.