The Goods and Services Tax Network (GSTN) has released a fresh set of additional FAQs to clear taxpayer concerns related to reporting of Input Tax Credit (ITC), reversals, and treatment of past-year entries in GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2024-25. The clarifications address long-standing ambiguities on cross-year ITC reporting, RCM disclosures, and reconciliation mismatches.
Below is a detailed summary of the official clarifications issued by GSTN.
1. RCM Paid in FY 2025-26 to Be Reported in GSTR-9 of FY 2025-26
GSTN clarified that RCM liability and related ITC paid in FY 2025-26 (even if pertaining to FY 2024-25) must be reported in GSTR-9 of FY 2025-26, not in FY 2024-25. This aligns with CBIC's earlier stance that RCM must be disclosed in the year of payment.
2. ITC of FY 2023-24 Availed in FY 2024-25 to Be Reported in Table 6A1
Taxpayers must report ITC of FY 2023-24 availed in FY 2024-25 under Table 6A1 of GSTR-9 for FY 2024-25. However, ITC reversal of FY 2023-24 made during FY 2024-25 should not be reported in Table 7, as Table 7 captures only current-year reversals.
3. Table 12B of GSTR-9C May Appear Redundant This Year
Since Table 7J of GSTR-9 does not include ITC of previous years, taxpayers may see mismatches in Table 12F of GSTR-9C.In such cases, the taxpayer may use Table 13 of GSTR-9C to provide reasons for unreconciled differences.
4. Differences May Arise Between Table 4C of GSTR-3B and Table 7J of GSTR-9
GSTN acknowledged that Table 4C of GSTR-3B may include ITC of FY 2023-24 claimed or reversed in FY 2024-25, whereas Table 7J of GSTR-9 shows only current-year ITC. This may lead to unavoidable mismatches.
5. ITC of FY 2023-24 Reversed in FY 2024-25 Not Required to Be Reported in GSTR-9
Any ITC pertaining to FY 2023-24 but reversed in FY 2024-25 is not required to be reported anywhere in GSTR-9 for FY 2024-25. Only reversals that pertain to the current financial year need to be reported.
6. ITC Reflected in 2B of FY 2023-24 but Availed in FY 2024-25
Where goods were received in FY 2024-25 but appeared in GSTR-2B of FY 2023-24, the ITC claimed in April 2024 must be reported in Table 6A1.
GSTN clarified that variations in GSTR-9C (Table 12A, 12E, 12F) may arise depending on accounting methodology, and taxpayers can justify differences in Table 13.
7. Non-GST Purchase Not Required in GSTR-9
GSTN confirmed that there is no table in GSTR-9 for reporting non-GST purchases. Hence, such details need not be included in the annual return.
8. Table 4G1 of GSTR-9 Applicable Only to E-Commerce Operators under Section 9(5)
Table 4G1 is to be filled only by e-commerce operators liable to pay tax under Section 9(5) of the CGST Act.
Official copy of the FAQs in tabular format has been attached
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