GST Annual Returns in GSTR 9 and 9C-Disussion on major amendment FY 2024-25 onwards

01-Nov-2025 , 12:32:10 pm | By Leena Rachh print

GST Annual Returns in GSTR 9 and 9C-Disussion on major amendment FY 2024-25 onwards

The CBIC, vide Notification No:13/2025-CT and Notification No:15/2025 -CT both dated 17^th 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:-

FAQs dt 15.1.25
Updated GSTR 9 and 9C on the portal.

A quick summary of major changes are 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 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 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

Rule 37 Non payment of supplier within 180 days
37A Suppliers failed to file GSTR 3B
38 Reversal for banking companies [50% ITC option]
42 Common ITC apportionment for taxable & exempt supplies
43 Capital goods ITC reversal
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 30^th 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.

CA Leena Rachh

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