The GSTN has released crucial FAQs clarifying annual return (GSTR 9) and reconciliation statement (GSTR 9C) filing for FY 2024-25. Key updates include the impact of GSTR-1A amendments on auto-population of Tables 4 and 5 in GSTR 9, ensuring that all revised supplies are reflected. The link between the new Invoice Management System (IMS) and GSTR 9 has been clarified: only accepted invoices in IMS appearing in GSTR-2B will populate Table 8A. The FAQ explains expected mismatches between Online and Excel Table 8A due to RCM supplies, amended POS, or date shifts. GSTR 9C introduces Table 17 for automatic calculation of late fees based on filing delays. Complex ITC reclaims under Rule 37/37A must now be reported in Table 6H, while other reclaims go to Table 6A1, with Table 6H delinked from Table 8B to avoid artificial differences. Filing GSTR 1 and 3B is mandatory before submitting GSTR 9/9C.The Goods and Services Tax Network (GSTN) has released important FAQs regarding the Annual Return (GSTR 9) and Reconciliation Statement (GSTR 9C) for FY 2024-25.
If you are preparing for year-end compliances, here are the 5 major changes and clarifications you cannot ignore:
1. GSTR-1A Now Impacts Auto-population For FY 2024-25, supplies added or amended through GSTR-1A will effectively be considered along with GSTR-1 and IFF for auto-populating Tables 4 and 5 of GSTR 9. This ensures your annual return reflects the most updated liability data automatically.
2. IMS & GSTR 9 Linkage Clarified Concerned about the new Invoice Management System (IMS)? The FAQs clarify that IMS actions do not directly impact GSTR 9. Instead, GSTR 9 continues to pull data from GSTR-2B. Only records accepted (or deemed accepted) in IMS that flow into GSTR-2B will populate Table 8A.
3. The “Table 8A” Mismatch Mystery Solved Do your Online Table 8A and Excel Download Table 8A figures mismatch? The FAQ confirms this is expected in specific scenarios, such as:
- RCM supplies (appear in Excel but not Online).
- Amended POS where the record becomes ineligible (appears in Excel with “No” eligibility, but excluded from Online).
- Invoice dates shifted between financial years.
4. New Late Fee Reporting in GSTR 9C A new Table 17 titled “Late Fee Payable and Paid” has been inserted in GSTR 9C.
- Late fees are calculated from the later of the GSTR 9 filing date or the due date.
- Example: If you file GSTR 9 on time but GSTR 9C is delayed by 7 days, the system auto-calculates late fees for those 7 days in this new table.
5. Complex ITC Reclaims (Rule 37 vs. Others) Reporting reclaims has become granular:
- Rule 37/37A Reclaims: If you reversed ITC in FY 23-24 and reclaimed it in FY 24-25 due to Rule 37/37A, it must go to Table 6H and not Table 6A1.
- Other Reclaims: Standard reclaims (non-Rule 37) go to Table 6A1.
- Note: Table 6H has been delinked from Table 8B to prevent artificial differences in Table 8D.
Pro Tip: You cannot file GSTR 9/9C until all GSTR-1 and GSTR-3B returns for FY 2024-25 are filed.
Time to update your reconciliation checklists!
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