GSTR-9C is the annual reconciliation statement under the Indian GST regime that aligns a taxpayer’s audited financial statements with the figures reported in GSTR-9, the annual GST return. It serves as a self-certified statutory compliance requirement for large taxpayers, replacing the earlier need for Chartered/Cost Accountant certification from FY 2020-21 onwards. The form identifies discrepancies in turnover, tax liability, and Input Tax Credit (ITC), ensuring transparency and reducing mismatches between books of account and GST filings. Key legal provisions include Section 44 of the CGST Act, 2017, and Rule 80(3) of the CGST Rules, which prescribe timelines, tables, and reporting obligations. GSTR-9C now includes e-commerce disclosures, ITC reconciliation logic, and late fee auto-computation. Taxpayers must reconcile current and preceding year ITC carefully, reporting claims, reversals, and reclaims in appropriate tables to prevent discrepancies. Filing deadlines are capped at three years from the due date, with exemptions for certain government departments and small taxpayers. Proper compliance strengthens audit readiness and reduces risk of penalties.
GSTR-9C – Annual Reconciliation Statement (self-certified statutory obligation)
In the Indian GST regime, GSTR-9C serves as the annual reconciliation statement that bridges the taxpayer’s audited financial statements with the GST annual return (GSTR-9) reported figures — essentially acting as a self-attested audit checkpoint of GST compliance. It provides assurance that numbers reported in GST returns match the audited books of accounts, thereby enhancing transparency and minimizing tax mismatches. Originally requiring certification by a Chartered/Cost Accountant, GSTR-9C has now evolved into a self-certified statutory obligation for large taxpayers, incorporating new tables, e-commerce disclosures, and enhanced ITC reconciliation logic — making it a key compliance deliverable in the GST cycle.
1. What Is GSTR-9C? —
Form GSTR-9C is a reconciliation statement under the GST regime that:
- Compares figures reported in the annual return(Form GSTR-9) against the audited annual financial statements (Profit & Loss, Balance Sheet, etc.) of the taxpayer.
- Identifies the unreconciled differencesin turnover, tax liability, and Input Tax Credit (ITC).
- Requires self-certification by the taxpayer (using Digital Signature or Aadhaar e-sign) for accuracy.
- Supports data integrity between GST returns and books of account for tax administration and audit risk assessment.
| Key Takeaways |
| 1. The need for a GST audit by CA/CMA stands removed for FY 2020-21 and any later financial years.
2. Every applicable taxpayer must submit a self-certified reconciliation statement by reconciling values between the audited financial statements and the annual returns. 3. Some taxpayers may be exempted from complying with the annual return and reconciliation statement requirement through the CBIC notification. 4. Section 44 shall not apply to any central government or state government departments already subject to audit by the Comptroller and Auditor-General of India (CAG). |
2. Statutory Basis: Legal Provisions & Rules
| Legal Provision | Summary |
| Section 44 of CGST Act, 2017 | Empowers CBIC to notify annual return and reconciliation statement requirements. |
| Rule 80 (3) of CGST Rules, 2017 | Prescribes Form GSTR-9C and its key tables (Turnover, ITC, Tax Paid, Differences, etc.). |
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| Section 44. Annual return. – |
| (1) Every registered person, other than an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person shall furnish an annual return which may include a self-certified reconciliation statement, reconciling the value of supplies declared in the return furnished for the financial year, with the audited annual financial statement for every financial year electronically, within such time and in such form and in such manner as may be prescribed:
Provided that the Commissioner may, on the recommendations of the Council, by notification, exempt any class of registered persons from filing annual return under this section: Provided further that nothing contained in this section shall apply to any department of the Central Government or a State Government or a local authority, whose books of account are subject to audit by the Comptroller and Auditor-General of India or an auditor appointed for auditing the accounts of local authorities under any law for the time being in force.] |
| (2) A registered person shall not be allowed to furnish an annual return under sub-section (1) for a financial year after the expiry of a period of three years from the due date of furnishing the said annual return:
Provided that the Government may, on the recommendations of the Council, by notification, and subject to such conditions and restrictions as may be specified therein, allow a registered person or a class of registered persons to furnish an annual return for a financial year under sub-section (1), even after the expiry of the said period of three years from the due date of furnishing the said annual return |
3. Due Dates & Recent Timeline Updates
| Financial Year | Due Date for GSTR-9 & 9C | Notes |
| FY 2024-25 | 31-Dec-2025 | Enabled for filing late in the year; stakeholders seek extension until March-2026 due to structural changes. |
| GSTR deadline rule | Returns cannot be filed after 3 years from original due date (effective 1-Jul-2025). |
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| Indore: Tax professionals and registered taxpayers in Madhya Pradesh have renewed their demand for a three-month extension of the deadline for filing GST annual return GSTR-9 and reconciliation statement GSTR-9C for FY 2024-25. They argue that this move would ease compliance pressure, improve the accuracy of filings, and reduce avoidable litigation. The current deadline is December 31, 2025. |
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| Circular No. 246/03/2025 clarifies the levy of late fees in relation to delayed furnishing of GSTR-9C. |
| The three-year time limit rule (effective from 1 July 2025) will prevent filing of past returns beyond three years from their due date. This also may affect late GSTR-9 / 9C filings. |
| GST Council (in 53rd meeting) recommended that for FY 2023-24, if annual turnover is below ₹ 2 crore, GSTR-9 / 9C filing may be waived (i.e. no requirement). |
| The late fee notification (No. 08/2025-Central Tax dated 23 January 2025) is the notification that grants the waiver for excess late fee for GSTR-9C filings for FY 2017-18 to 2022-23, if filed by 31 March 2025. No refund for late fees already paid |
4. Structure of Form GSTR-9C — Parts & Tables
Annual Reconciliation Statement
FY 2024-25
Form GSTR-9C
[See Rule 80(3)]
5. Recent Key Changes
A. Self-Certification Only
The requirement for a CA/CMA signature has been removed for FY 2020-21 onwards — taxpayers self-certify true reconciliation.
B. New Tables & Disclosures
- Table 7D1:Captures turnover related to e-commerce operator supplies (Sec 9(5)).
- Late Fee Table 17:Auto-computes daily late fees under Section 47(2).
- Clear distinction between “tax payable” and “tax paid” in liability reconciliation — aligning with compliance dynamics. (TaxGuru)
Consolidated FAǪ on GSTR 9/9Cfor the FY 2024-25
1. When my GSTR 9/9C for FY 2024-25 will be enabled?
Once all the due returns in Form GSTR 1 and GSTR 3B for the FY 2024-25 is filed, GSTR 9/9C for FY 2024-25 will be enabled in the system automatically.
2. If any GSTR 1 and GSTR 3B is pending for the FY 2024-25 then will my GSTR 9 is enabled?
No GSTR 9 will not be enabled where any GSTR 1 and GSTR 3B is pending for FY 2024-25. All the relevant cells of Table 4,5,6,8 and 9 of GSTR 9 will be auto populated based on the statement / return filed by you i.e. GSTR 1/1A/IFF or GSTR 2B or GSTR 3B.
3. What is table 8A of GSTR 9 and how it will be auto populated?
Table 8A of GSTR 9 for FY 2024-25 capture the details of documents / records pertaining to FY 2024-25 appearing in GSTR 2B. Therefore, 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
Also include the invoices pertaining to FY 2024-25 appearing in GSTR 2Bof next year 2025-26 between April 2025 to October 2025 and
exclude the invoices pertaining to previous FY 2023- 24 appearing in GSTR 2B between April 2024 to October 2024.
4. Is there any impact on GSTR-9 due to action taken on IMS Dashboard?
IMS does not have direct impact on GSTR 9. The documents/records which are accepted or deemed accepted would have appeared in GSTR 2B and hence will form part of Table 8A of GSTR 9 for FY 2024-25 as discussed at Sr. No. 3. As GSTR 9 will take the data from GSTR 2B where GSTR 3B has already filed.
5. Will the supplies added / amended through GSTR 1A be considered for auto population of value in Table 4/5 of GSTR 9?
Yes, from FY 2024-25 the supplies added / amended through GSTR 1A will also be considered along with GSTR 1 and IFF for the purpose of auto population in Table 4, 5 of GSTR 9.
6. What is table 6A1 and which amount is required to be reported?
Table 6A1 of GSTR 9 for FY 2024-25 capture the ITC of preceding FY (2023-24) claimed by the recipient in the current FY (2024-25) till the specified time period and it is also included in Table 6A of GSTR 9 for FY 2024-25.
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 Table 6A2 (6A minus 6A1) is the ITC pertaining to current FY (2024-25) which need to be bifurcated between 6B to 6H.
As the ITC of preceding FY (2023-24) has been excluded through Table 6A1 therefore it will not create the difference in Table 6J of GSTR 9 as the case was with GSTR-9 till FY 2023-24. Consolidated FAǪ on GSTR 9/9Cfor the FY 2024-25 Page 2 of 13
7. How the value of ITC will be reported 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.
Example 1 – Mr A has claimed Rs 100 (IGST) in the month of April 2024 and reversed the same in October 2024 due to nonpayment to Supplier within 180 days as per rule 37 of CGST Rule 2017.
The same has been reclaimed in March 2025 as payment has been made on 4 th March 2025. The reporting will be in the GSTR 9 for FY 2024-25 as under –
1. Original claim in Table 6B of GSTR 9 for FY 2024-25
2. Reversal of same in Table 7A of GSTR 9 for FY 2024- 25
3. Reclaim in Table 6H of GSTR 9 for FY 2024-25
Example 2 – Mr A has claimed Rs 100 (IGST) in the month of April 2024 and reversed the same in April 2024 due to non- receipt of goods as per Circular No. 170/02/2022-GST 6th July 2022. The same has been reclaimed in May 2024 as goods has been received on 4th May 2024. The reporting will be in the GSTR 9 for FY 2024-25 as under –
1. Original claim in Table 6B of GSTR 9 for FY 2024-25
2. Reversal of same in Table 7H of GSTR 9 for FY 2024- 25
3. Reclaim in Table 6H of GSTR 9 for FY 2024-25
8. How the value of ITC will be reported if ITC pertaining to FY 2023- 24 has been claimed, reversed in FY 2023- 24 and 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.
Example 1 – If any ITC pertaining to preceding FY (2023-24) was claimed and reversed in the preceding FY (2023-24) but reclaimed (Other than rule 37/37A like Circular No. 170/02/2022-GST 6th July, 2022 etc.) in the current FY (2024- 25) till the specified time period (i.e. 30th November 20241 ) then such reclaimed ITC to be reported in Table 6A1 of GSTR 9 for FY 2024-25. It will not come in Table 6H of GSTR 9 of FY 2024-25.
Example 2 – If any ITC pertaining to preceding FY (2023-24) was claimed and reversed in the preceding FY (2023-24) but reclaimed 1 Substituted the word “2025” with “2024” which is in line with the provision of Section 16(4) of CGST Act 2017. Consolidated FAǪ on GSTR 9/9Cfor the FY 2024-25 Page 3 of 13 (due to rule 37/37A) in the current FY (2024-25) then such reclaimed ITC should not be reported in Table 6A1 of GSTR 9 for FY 2024-25. This needs to be reported in Table 6H of GSTR 9 for FY 2024-25.
9. How the value of ITC will be reported if ITC pertaining to FY 2024- 25 has been claimed, reversed in FY 2024- 25 and reclaimed in the FY 2025-26?
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. As ITC was claimed and reversed in the FY 2024-25 itself then it will be reported in table 6B and reversal in Table 7 of GSTR 9.
In such cases 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).
Example 1 – If any ITC of current FY (2024-25) was claimed and reversed in the FY (2024-25) but reclaimed (Other than rule 37/37A like Circular No. 170/02/2022-GST 6th July 2022 etc) in the next FY (2025-26) till the specified time period (i.e. 30th November 2025) then such ITC will be reported in GSTR 9 as under –
1. Original claim shall be reported in Table 6B of GSTR 9 for FY 2024-25
2. Reversal of same shall be reported in Table 7H of GSTR 9 for FY 2024-25
3. Shall not report reclaim amount in Table 8C of GSTR 9 for FY 2024-25
4. Reclaim shall be reported in table 13 of GSTR 9 for FY 2024-25
5. Reclaim shall be reported in table 6A1 in next FY 2025- 26 (in GSTR 9 of next Year).
Example 2 – If any ITC of current FY 2024-25 was claimed and reversed in the FY 2024-25 but reclaimed (due to rule 37/37A) in the next FY 2025-26 then such ITC will be reported in GSTR 9 as under –
1. Original claim shall be reported in Table 6B of GSTR 9 for FY 2024-25 Consolidated FAǪ on GSTR 9/9Cfor the FY 2024-25 Page 4 of 13
2. Reversal of same shall be reported in Table 7A (rule 37) or 7A1 (rule 37A) of GSTR 9 for FY 2024-25 3. Reclaim shall not to be reported in table 8C and 13 of GSTR 9 for FY 2024-25
3. Reclaim shall be reported in table 6H of GSTR 9 for FY 2025-26 (in GSTR 9 of next Year).
10. Whether there are any changes in the reporting fortable 6M as label has been changed from FY 2024-25 ?
No. Label change to Table 6M has aligned it with the instruction of the notified form. As per the Instruction to the notified form the ITC claimed through ITC 01, 02 and 02A should be reported in Table 6M of GSTR 9.
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Disclaimer: This article is prepared solely for educational and informational purposes and is based on the provisions of the CGST Act, 2017, related Rules, Notifications, Circulars, and other statutory material available as on the date of publication. While due care has been taken to ensure accuracy, the author does not assume any responsibility for errors, omissions, or consequences arising from the use of this information. The views expressed are based on professional interpretation and should not be treated as legal or tax advice. Readers are advised to verify the applicable law independently and seek professional guidance before taking any decision.
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