Important aspects in filing of GSTR 9 considering recent changes for FY 24-25

Introduction

This article aims to provide clarity on the filing of annual returns (Form GSTR 9) along with recent changes as applicable for Financial Year 2024-25.

Applicability

1. GSTR 9 needs to be filed if aggregate turnover of Registered Taxpayer exceeds Rs 2 crores.

2. GSTR 9/9C for FY 2024-25 will be enabled in the system automatically when all the due returns in GSTR 1 and GSTR 3B for the FY 2024-25 are filed.

Input Tax Credit – Availed & Reversed

1. Table 6A1 which is a new Table, capture the ITC of preceding FY (2023-24) claimed by the recipient in the current FY (2024-25) till the specified time period. However, any ITC pertaining to FY 2023-24 or any other preceding financial years, which has been reclaimed during current FY (2024-25) on account of rule 37 / 37A will not be reported in Table 6A1 of GSTR 9. Therefore, the amount calculated in new Table 6A2 (6A minus 6A1) is the ITC pertaining to current FY (2024-25) which need to be bifurcated between 6B to 6H.

2. If ITC pertaining to FY 2024- 25 has been claimed, reversed and reclaimed in the same FY 2024-25, Table 6A of GSTR 9, is auto populated from Table 4A (1 to 5) of GSTR 3B for entire FY from April 2024 to March 2025. Therefore, in the given case this amount will appear twice in Table 6A of GSTR 9 i.e. once for claim and second for reclaimed amount. In such cases these three events should be reported as below –

• claim should be reported in Table 6B,

• reversal should be reported in Table 7 (Table 7A to 7H, as the case may be) and

• reclaimed should be reported in 6H.

3. If ITC pertaining to FY 2023- 24 has been claimed and reversed in FY 2023- 24 but reclaimed in the FY 2024-25, ITC pertaining to preceding FY (2023-24) which has been claimed / reclaimed in this FY (2024-25) for any reason other than rule 37/37A, should be reported in Table 6A1 as this ITC is also included in Table 6A above. Further, any ITC which is reclaimed for the reason rule 37/37A should be reported in Table 6H as this ITC is also included in Table 6A above.

4. If ITC pertaining to FY 2024- 25 has been claimed, reversed in FY 2024- 25 and reclaimed in the FY 2025-26, these two events should be reported as below –

• claim should be reported in Table 6B,

• reversal should be reported in Table 7 (Table 7A to 7H, as the case may be).

For the reclaim the procedure will be based on whether reclaim is on account of rule 37/37A or reason otherwise, as below –

A. If the ITC which was reclaim in FY 2025-26 is because of other than rule 37/37A, such reclaim will be reported in Table 13 of GSTR 9 for FY 2024-25 and table 6A1 of GSTR 9 of FY 2025-26 (in GSTR 9 of next Year). This will not be reported in Table 6H of GSTR 9 of 2025-26 (in GSTR 9 of next Year).

B. If the ITC which was reclaim in FY 2025-26 is because of reason rule 37/37A, such reclaim will be reported in the Table 6H of GSTR 9 of 2025-26 (in GSTR 9 of next Year). This is not to be reported in table 13 of GSTR 9 of FY 2024-25 (Current year) and Table 6A1 of GSTR 9 of FY 2025-26 (in GSTR 9 of next Year).

5. The ITC which is claimed and reversed due to reason of rule 37 / 37A and subsequently reclaimed in any financial year, then such reclaimed ITC will always be considered the ITC of that year in which it has been reclaimed. Therefore, it will always be reported in Table 6H of GSTR 9 to be filed for the FY in which such reclaim has been reported.

Other ITC related information

1. Table 8A of GSTR 9 will include all the inward supplies pertaining to FY 2024-25 appearing in GSTR 2B of FY 2024-25 and will

i. also include the invoices pertaining to FY 2024-25 appearing in GSTR 2B of next year 2025-26 between April 2025 to October 2025 and

ii. exclude the invoices pertaining to previous FY 2023- 24 appearing in GSTR 2B between April 2024 to October 2024.

2. In case supplier reported the Invoice/DN/CN for the FY 2024-25 up to the specified time of next FY, then such record will be auto populated in the Table 8A of GSTR 9 for FY 2024-25 automatically after filling of GSTR 3B for corresponding tax period.

3. To facilitate the taxpayer, the amount auto populated in Table 8A online, invoice wise details is being provided in excel sheet on the GSTR 9 dashboard AS ‘DOWNLOAD TABLE 8A DOCUMENT DETAILS’. Taxpayer can download and refer the Invoices/DN/CN based on which amount is auto populated in the Table 8A online.

4. Table 8C contain data of ITC of current FY which is availed in next FY within the specified time period. This table shall not include any ITC which was claimed (reported in table 4A of GSTR 3B) and reversed (Reported in 4B of GSTR 3B) in the current FY and reclaimed in next FY till the specified time period. Hence the Table 8C only contain the missed ITC of current FY (2024-25) which is claimed in GSTR 3B of next FY till the specified time period.

Amount will be reported in Table 8C only when

i. The ITC pertaining to the FY 2024-25 which is part of GSTR 2B and auto populated in Table 8A of GSTR 9 but which has not been claimed by the recipient during the FY 2024-25 and hence he is availing the corresponding ITC first time in Table 4A5 of GSTR 3B of next FY (2025-26) till the specified time period.

ii. The supplies pertaining to the FY 2024-25 which the supplier has not reported in any GSTR 1 filed during FY 2024-25 and reported in GSTR 1 furnished between April’25 to October 2025 and hence recipient is availing the corresponding ITC first time in table 4A5 of GSTR 3B of next FY (2025-26) till the specified time period.

5. If goods have been imported in FY 24-25 but the ITC has been taken in FY 2025-26, it will be reported in the new inserted Table 8H1 and it will not be reported in the Table 6E of GSTR 9. IGST Paid on import of goods be reported in Table 8G, ITC availed in the financial year to be mentioned in Table 8H 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.

Details of Tax Paid

The Tax payable column is captured from GSTR 3B from net liability. If liability reported in the Table 6.1 of GSTR 3B is positive (Gross minus negative liability) then such positive net tax liability be auto populated in the Table 9 under tax payable. However, if net amount in Table 6.1 is appearing in negative, then no amount will be auto populated under Tax payable column of Table 9.

Further tax payable column of Table 9 of GSTR 9 is kept editable and therefore taxpayer may change the value, if required.

Earlier, additional tax liability can be discharged only through Cash. For FY 2024-25, it can be paid through Cash or Electronic Credit Ledger.

Particulars of the transactions for the financial year declared in returns of the next financial year

Tables 12 and 13 which were optional for FY 2023-24 are made mandatory for FY 2024-25. Table 12 contains details of ITC of the financial year reversed in the next financial year. Table 13 contains details of ITC of the financial year availed in the next financial year.

HSN wise Summary of Outward Supplies

To facilitate the taxpayer, additional excel sheet named as ‘DOWNLOAD TABLE 12 of GSTR 1/1A HSN DETAILS’ is provided having the consolidated details of Table 12 of GSTR 1 and additional sheet have also been provided in the same excel sheet having the details of HSN in the format of Table 17 of GSTR 9. This will facilitate the taxpayer to use the download file and report the same in Table 17 of GSTR 9 for FY 2024-25.

Late Fee

As clarified vide Circular No. 246/03/2025-GST dated 30th January 2025, the late fee is levied under Section 47(2) of the CGST Act for any delay in furnishing the complete annual return under Section 44. This includes both FORM GSTR-9 and FORM GSTR-9C (if applicable). Accordingly, a new Table - 17 titled "Late Fee Payable and Paid" has been inserted below Part V of GSTR-9C to capture such late fee payable under Section 47(2).

The late fee shall be leviable for the period starting from the due date of furnishing the annual return till the date of filing of GSTR 9 for annual return. The late fee for GSTR 9C will be calculated from date of filing of GSTR 9 or due date of filing of Annual return, whichever is later till the filling of GSTR-9C. These late fees will be auto calculated by the system based on the date of filing of GSTR 9 and 9C.