The Consolidated FAQ on GSTR-9/9C for FY 2024-25 reaffirm that annual GST filings are not mere formalities but legally significant, forensic documents that often trigger scrutiny, audit, and litigation. The clarifications stress that GSTR-9 is a final, non-revisable statement of facts, while GSTR-9C requires careful reconciliation rather than forced matching. Auto-populated data, though helpful, only reflects past filings and may perpetuate earlier errors if not reviewed. Particular emphasis is placed on ITC reporting—especially Table 8A reconciliation with GSTR-2B, correct treatment of reversals and reclaims, and proper classification between Tables 6, 7, 8 and 13. The FAQs also clarify treatment of imports, RCM, timing differences, and introduce system-driven late fee computation. Overall, the guidance underlines that accurate mapping, documented explanations, and thoughtful disclosures are essential to avoid disputes, as annual returns increasingly form the foundation of GST enforcement actions. In this article, let us distil those clarifications into practical guidance.
1. GSTR-9 & 9C: Not Just a Summary, But a Statement on Oath
Legally speaking:
- GSTR-9 is the annual return under Section 44 of the CGST Act.
- GSTR-9C is a reconciliation statement between audited financials and GST returns, certified by the taxpayer (self-certification regime).
What often goes unnoticed is that errors in GSTR-9/9C are not easily correctable. Unlike monthly returns, revisions are not permitted. Whatever is filed becomes the taxpayer’s final narrative for that year.
2. Auto-Population: Helpful, But Not Infallible
A recurring misconception is that auto-populated data is “safe”. The FAQ makes it clear that:
- Tables 4, 5, 6, 8 and 9 of GSTR-9 are auto-populated from GSTR-1, GSTR-1A, IFF, GSTR-2B and GSTR-3B.
- GSTR-9 will not even be enabled unless all GSTR-1 and GSTR-3B returns for the year are filed
Practical insight:
Auto-population reflects what was filed, not what was correct. If errors exist in monthly returns, GSTR-9 will faithfully reproduce them — and silently lock them in.
3. Table 8A: The Heart of ITC Reconciliation
One of the most litigated tables is Table 8A, which captures ITC as per GSTR-2B.
- Table 8A includes invoices of FY 2024-25 appearing in GSTR-2B up to October 2025 (the statutory cut-off).
- It excludes invoices of earlier years, even if they appear later in 2B.
- An invoice-wise Excel utility is provided on the GST portal to explain how 8A is populated — and it may differ from the online view due to technical filters
Action point:
Never rely only on the online figure. Download the Table 8A Excel, identify exclusions, and document reasons — this becomes critical during audit.
4. ITC Claimed, Reversed, and Reclaimed: The Most Common Mistake Zone
The FAQ devotes substantial attention to ITC lifecycle issues — for good reason.
ITC of Earlier Years Claimed in Current Year
- Such ITC must be reported in Table 6A1, not mixed with current-year ITC.
- Reversals of earlier-year ITC in the current year should not be reported in Table 7
Reclaim under Rule 37 / 37A
- Reclaimed ITC is treated as ITC of the year of reclaim, not the original invoice year.
- It must be reported in Table 6H of the year in which reclaim happens
Why this matters?
Incorrect mapping between Tables 6, 7, 8 and 13 is one of the biggest triggers for ITC mismatch notices and DRC-01 proceedings.
5. Table 8C vs Table 6H: A Subtle but Critical Distinction
A frequent error is reporting reclaimed ITC in Table 8C.
The FAQ clearly clarifies:
- Table 8C is only for “missed ITC” of the current year, claimed for the first time in the next financial year.
- ITC that was claimed, reversed, and later reclaimed must never go into 8C, as it will distort Table 8D reconciliation
This clarification alone can prevent many unnecessary disputes.
6. Imports, RCM and Timing Differences
Important clarifications include:
- IGST on imports paid in one year but claimed in the next year must be split between Table 8G and newly inserted Table 8H1.
- RCM liability and ITC are to be reported in the year of payment, not the year of accrual, consistent with earlier CBIC clarifications
7. GSTR-9C: Reconciliation Is Not About Matching at Any Cost
A dangerous mindset is trying to “force-match” figures between books and returns.
The FAQ recognises that:
- ITC treatment in books depends on accounting methodology.
- Genuine differences should be explained in Table 13 of GSTR-9C, not artificially adjusted
Professional tip:
A well-reasoned explanation in Table 13 is far safer than an artificial reconciliation that collapses during scrutiny.
8. Late Fees: Now Explicit and System-Driven
From FY 2024-25:
- Late fee under Section 47(2) applies to complete annual return, i.e., GSTR-9 + GSTR-9C together.
- A dedicated table has been inserted in GSTR-9C, and the system auto-calculates delay based on filing dates
9. Practical Takeaways for Businesses & Professionals
- Treat GSTR-9 as a legal statement, not a compliance chore.
- Perform ITC lifecycle mapping before touching Tables 6, 7 and 8.
- Always reconcile Table 8A Excel vs online view.
- Use Table 13 of GSTR-9C confidently to explain genuine differences.
- Maintain a working paper trail — FAQs are persuasive, but documentation wins disputes.
Closing Remarks:
GSTR-9 and 9C are no longer passive compliance forms. They are increasingly becoming the starting point of GST litigation. The latest FAQs provide clarity, but clarity helps only those who read, understand, and apply it thoughtfully.
As professionals, our role is not just to file — but to tell the right story, backed by law and numbers.
******
In case of any query and clarification regarding Taxation, GST, FEMA and International Taxation and require any support, you may like to connect with us.
Abhinarayan Mishra FCA, FCS, LL.B, IP, RV; Partner, KPAM & Associates, Chartered Accountants, SAM Law Associates LLP. New Delhi ; +91 9910744992; ca.abhimishra@gmail.com; samlawassociates18@gmail.com
Author Bio
Comments are closed.