GST Annual Returns in GSTR 9 and 9C: Discussion on major amendments FY 2024-25 onwards

The CBIC, vide Notification No: 13/2025-CT and Notification No: 15/2025-CT both dated 17th September, 2025, has made several significant amendments to the annual Returns in Forms GSTR 9 and GSTR 9C. These changes are applicable w.e.f. FY 2024-25. This notification was followed by the following:

a. FAQs dt 15.1.25

b. Updated GSTR 9 and 9C on the portal.

A quick summary of major changes is as under:

Permanent relief to small taxpayers

Vide notification No:15/2025-CT dt 17.09.25, permanent exemption from filing GSTR 9 has been granted to taxpayers having aggregate turnover less than 2 crores. This extends the relief provided in FY 2023-24 [NN 14/2024-CT dt 10.07.2024]

Filing of all GSTR 1 and GSTR 3B for the financial year is mandatory

GSTR 9 /9C unlocks only after all GSTR 1 and GSTR 3B of the financial year are filed.

Introduction of Tables 6A1 and 6A2

• 6A1 introduced this year pertains to ITC of preceding FY other than ITC reclaimed under Rule 37 and 37A, which is included in Table 6A [which pertains to total ITC availed through GSTR 3B]
• 6A2=Net ITC for the financial year [after excluding 6A1]

Changes in the reporting of reclaimed ITC

• First time claim to be reported in Table 6B
• Reversal to be reported in Table 7
• Reclaimed ITC to be reported in Table 6H
• ITC reversed due to Rule 37/37A in earlier years and now reclaimed to be reported in Table 6H.
• Any other ITC reversed in earlier year but claimed in current year to be reported in Table 6A(1).

Expansion of Table 6M

• Wordings modified the same is no longer a residual cell.
• Earlier it was "any other ITC availed but not specified above". However from FY 2024-25 the wordings of Table 6M are "ITC availed through ITC-01, ITC-02 and ITC-02A."
• Table 6M will now capture ITC availed through ITC-01 [credit on new registration] and ITC-02/02A [credit transfer on merger/demerger, business transfer]. This brings greater transparency in ITC reporting.

Rule-wise reporting of ITC Reversals

· Consolidated reporting of ITC reversals, as done earlier, to be replaced by Rule-wise reporting of ITC reversals under

(i) Rule 37 Non-payment of supplier within 180 days

(ii) 37A Suppliers failed to file GSTR 3B

(iii) 38 Reversal for banking companies [50% ITC option]

(iv) 42 Common ITC apportionment for taxable & exempt supplies

(v) 43 Capital goods ITC reversal

(vi) Sec. 17(5] Blocked credit

New disclosures for import

• Table 8H1 introduced for IGST credits on import of goods claimed in next financial year.
• Separate reporting of deferred ITC and IGST credit on imports claimed in the current year

Auto population figures

Figures in tables 4,5, 6, 8 & 9 are autopopulated based on returns already filed.

From FY 2024-25 onwards amendments made through GSTR 1A will also be considered in Tables 4 & 5.

Other changes

• Table 9-Enhanced reconciliation between tax liability and tax paid, with clearer splits [Cash vs ITC] and stricter validations.
• Tables 10,11, 12 & 13 have undergone cosmetic changes
• Tables 12 & 13 are now mandatory -ITC of FY 2024-25 claimed and reversed in GSTR 3B of FY 2025-26 [before 30th November, 2025]
• Auto population of late fees under Sec. 47(2) of the CGST Act, 2017.

Amendments in GSTR 9C

A new line item requiring separate disclosure of supplies where tax is payable by E-Commerce Operator.

Hence, annual returns FY 2024-25 onwards are not just routine compliance returns. They are macro-level reporting requiring accurate, rule-wise and period-wise documentation. Meticulous record keeping throughout the year is the only way to ensure smooth filing and accurate reconciliation.