GSTR-9 FY 2025-26: New GST Rates, HSN Reporting and ITC Changes

Summary: Form GSTR-9 for FY 2025-26 introduces practical reconciliation challenges arising from the GST rate changes effective 22 September 2025 and expanded portal-based reporting. Businesses must review transactions falling before and after the rate revisions, verify applicable rates and reconcile the annual return with their outward supply records. The article explains the portal’s pre-population of HSN-wise outward supply details in Table 17, the offline utility for taxpayers with more than 500 HSN entries, and the importance of checking missing or incorrect entries. It also examines the enhanced Table 8A document-level download, including ITC considered by the portal, exclusion reasons and the treatment of invoice amendments. Changes to auto-populated figures are highlighted, making supporting reconciliations particularly important. The article further discusses filing relaxations stated to continue for FY 2025-26, including simplified disclosure of certain supplies and input tax credit categories, optional tables and separate reporting of ITC reversals. It identifies the general turnover thresholds for GSTR-9 and GSTR-9C, the statutory filing deadline of 31 December 2026, the Section 16(4) ITC time limit and the consequences of delayed or incorrect filing. Since the annual return cannot ordinarily be revised after submission, taxpayers should reconcile GSTR-1, GSTR-3B, GSTR-2B, books of account and HSN-wise data before filing.

GSTR-9 for FY 2025-26: What Is Different This Year

The GST annual return for FY 2025-26, Form GSTR-9, can now be filed on the GST portal. Larger businesses must also file Form GSTR-9C, a statement that matches the return with their audited accounts. The last date for both is 31 December 2026.

The forms look the same as last year, but filing them will not be. Here are the changes every business should know about.

One Financial Year, Two GST Rate Structures

GST rates changed on 22 September 2025. Many goods moved to new rates, and the 12% and 28% slabs were removed. So FY 2025-26 has two parts:

• 1 April to 21 September 2025: old rates
• 22 September 2025 to 31 March 2026: new rates

What this means: If the rate of a product changed during the year, its sales must be shown in two lines in the return, one at the old rate and one at the new rate.

What to do: Divide your sales and purchase records at 21/22 September. Check that no bill dated after 21 September carries an old rate. If you issued a credit note after 22 September for a sale made earlier, use the old rate on it.

HSN-Wise Outward Supply Details in Table 17

Every return has a table (Table 17) that lists sales product-wise, by HSN code. Until last year, businesses filled this in themselves. From this year, the portal fills it in automatically from GSTR-1, the monthly sales return.

But the portal itself warns that some entries may fail to load. When that happens, the missing entry does not appear on screen or in the downloadable Excel, and nothing tells you it is missing.

Offline Utility for More Than 500 HSN Entries

If a business has more than 500 HSN entries, the portal will not show them online. It must use the offline utility:

1. Download the data as a file.
2. Check and correct it in the offline tool.
3. Upload it back to the portal before filing.

What to do: Do not accept the pre-filled figures as they are. Check that the total of this table matches your total sales and your monthly GSTR-1 returns.

Table 8A: How the Portal Calculates Input Tax Credit

ITC is input tax credit: the GST paid on purchases that a business can set off against its own GST. In the annual return, one figure (Table 8A) shows how much ITC the portal says was available to you. Until now, the Excel behind this figure rarely matched it, and nobody could easily tell why.

This year the Excel shows, for every bill:

• how much ITC the portal actually counted, and
• the reason, where it did not count a bill.

Reasons for ITC Exclusion

The reasons given are:

• the supplier entered the wrong State as the place of supply;
• the purchase falls under reverse charge, where the buyer pays the tax;
• the supplier filed its return too late for the ITC to be allowed;
• the buyer’s GSTIN on the bill was changed.

How Invoice Amendments Affect ITC

The Excel also handles corrected bills differently. When a supplier corrects a bill, the portal now counts only the difference from the original. For example:

• If the supplier only corrected the bill number, the portal counts nothing extra.
• If the supplier cut a bill to almost zero instead of issuing a credit note, the portal reduces your ITC by that amount.

What to do: Use the “ITC considered” column when matching your ITC. Look at every bill the portal did not count and read the reason. Where the supplier made the mistake, ask the supplier to correct it.

Changes to Pre-Filled Figures Are Highlighted in Red

Where you change a figure the portal has filled in, the box turns red, and it stays red even after filing. This started last year. It matters more now because the portal fills in much more of the return, so the officer reviewing it can easily see every change you made.

What to do: Keep a written explanation, with supporting working, for every figure you change.

Reporting Relaxations for FY 2025-26

The article describes certain reporting relaxations for FY 2025-26. However, Notification No. 05/2026-Central Tax dated 26 October 2026 concerns CGST Rules amendments and should not be cited as authority for the following GSTR-9 relaxations without separate verification: Notification No. 05/2026-Central Tax

• exempt and nil-rated sales can be shown together;
• ITC on inputs and on services can be shown together;
• Tables 15, 16 and 18 can be left blank;
• in GSTR-9C, some tables can be combined, and Table 14 is optional.

There is one exception. Where ITC was reversed, each reversal must still be shown separately against its rule. It cannot be put together under one heading.

Who Must File GSTR-9 and GSTR-9C?

• Turnover up to ₹2 crore: GSTR-9 is optional.
• Turnover above ₹2 crore: GSTR-9 must be filed.
• Turnover above ₹5 crore: GSTR-9 and GSTR-9C must both be filed.

The return can be filed only after all monthly returns for the year (GSTR-1 and GSTR-3B) have been filed.

Important Dates, Late Fees and Revision Restrictions

• 30 November 2026: last date to claim any ITC for FY 2025-26 that you have not yet claimed.
• 31 December 2026: last date to file GSTR-9 and GSTR-9C.
• Late fee: it is charged for every day of delay, and keeps running until GSTR-9C is also filed. Do not file GSTR-9 alone and leave GSTR-9C for later.
• No corrections: once filed, the return cannot be revised. It also cannot be filed at all after three years from the due date.

Practical Checklist Before Filing GSTR-9

This year the portal does more of the work, but businesses still need to check it. Divide the year at 22 September, check the pre-filled HSN figures, go through the ITC reasons bill by bill, and keep a record of every change you make. Finish this checking before November ends, so that December is left only for filing.