As the GST portal enables GSTR-9 filing from October 13, 2025, with a December 31 deadline, taxpayers are gearing up for annual returns. For FY 2024-25 (April 2024-March 2025), the Central Board of Indirect Taxes and Customs (CBIC) has introduced targeted updates via Notification 16/2025 to streamline Input Tax Credit (ITC) reporting and reduce discrepancies. These tweaks aim to align data better with actual transactions, but they demand extra vigilance to avoid notices.
Key Takeaways
- Verify Document Dates Religiously: Table 8A's shift to date-based logic could pull in "future" ITC, risking over-claims; reconcile with GSTR-2B monthly.
- Leverage Offline Tools: Use the GST portal's Excel utility for JSON uploads to test data before submission-edits are locked post-filing.
- GSTR-9C Spotlight: New Tables 12B & 12C mandate ITC disclosures per books vs. returns; auditors must certify for accuracy.
- Deadline Alert: December 31, 2025-beat the rush to avoid system glitches.
Major Updates in GSTR-9
Table 8A Integration with Invoice Management System (IMS):
Auto-population now pulls from IMS and GSTR-2B based on the document date (not the reporting period). This means invoices dated FY 2024-25 will appear here, even if they show up in later GSTR-2B summaries (e.g., April-October 2025). Expect potential mismatches with Table 8C-double-check to prevent DRC-01 notices.
Revised Table 8C Rules:
Computation logic for ITC reconciliation has been overhauled, factoring in IMS data for more accurate reversals and claims. This could flag inconsistencies if your books don't match portal data.
New Table 6A1 for Cross-Year ITC Tracking:
A fresh sub-table segregates ITC claimed, reversed, or reclaimed from prior years, enhancing transparency on carry-forwards.
Impact of GSTR-1A Amendments:
Changes filed via the new GSTR-1A form will auto-reflect in Tables 4 (outward supplies) and 5 (tax adjustments), simplifying corrections without manual tweaks.
No Major Threshold Shifts:
GSTR-9 remains mandatory for turnovers > ₹2 crore (optional below); GSTR-9C kicks in above ₹5 crore. Late fees: ₹200/day (max 0.25% of turnover).
These changes, notified on September 17, 2025, focus on precision but may increase reconciliation time.
Year-Over-Year Comparison: GSTR-9 Evolution
| Aspect | FY 2023-24 | FY 2024-25 (New) |
| ITC Auto-Population | GSTR-2B period-based only | IMS + Document Date integration |
| Reversal Logic | Manual prorations | Auto-IMS factored computations |
| Prior ITC Tracking | Embedded in Table 6 | Dedicated Table 6A1 for segregation |
| Amendments Impact | Manual Table 4/5 edits | Auto via GSTR-1A |
| GSTR-9C Mandates | Basic reconciliations | Variance schedules (>5%) + E-signing |
| Filing Window | Oct 1-Dec 31, 2024 | Oct 13-Dec 31, 2025 (post-1/3B mandatory) |
FAQs
When is filing enabled?
From October 12, 2025, but only after completing all GSTR-1 & 3B for the year.
Who must file GSTR-9C?
Businesses with aggregate turnover > ₹5 crore; optional EVC/DSC signing applies.
Can I edit auto-populated data?
Yes, but reconcile thoroughly-GSTR-9C pulls from GSTR-9 and locks on submission.
What if the filing is late?
₹200/day penalty (₹100 CGST + ₹100 SGST), capped at 0.25% of turnover; GSTR-9C must follow immediately.
Is Offline filing possible?
Absolutely-download the utility, validate schema, and upload JSON to dodge portal errors.
Are Revisions allowed?
No for either form; download filed copies from "View Filed Returns" for records.
What is the Auditor's role in GSTR-9C?
Mandatory certification on ITC reconciliations; attach audited statements and schedules.
CAclubindia
