The Institute of Chartered Accountants of India (ICAI), through its GST & Indirect Taxes Committee, has submitted suggestions to improve the structure and reporting in GST Annual Return (Form GSTR-9) and Reconciliation Statement (Form GSTR-9C). For GSTR-9, suggestions include bifurcating exempted supplies reporting, clarifying the inclusion of Schedule III transactions in non-GST supply disclosure and its impact on turnover calculation for late fees, and resolving complexities in reporting and reconciling Input Tax Credit (ITC) that is claimed, reversed, and subsequently reclaimed across different tables (6, 7, 8). The ICAI also proposed changes to accurately reflect unclaimed IGST on imports carried forward, allow payment of additional liability using credit, and provide clearer instructions for reporting transactions and amendments spanning across financial years (Tables 10, 11). Simplifying the HSN summary auto-population from GSTR-1 was also suggested. For GSTR-9C, the suggestions focus on enhancing the detail for reporting turnover adjustments (Table 5O), incorporating the reporting of supplies taxable under Section 9(5) through E-commerce Operators (Table 7, 9) to ensure proper reconciliation, and modifying tables (9Q, 11) to include interest/penalty and ITC utilization for comprehensive tax payment reconciliation. These proposals aim to simplify compliance, enhance reporting accuracy, and address current challenges faced by taxpayers and professionals.
THE INSTITUTE OF CHARTERED
ACCOUNTANTS OF INDIA
SUGGESTIONS ONN
FORMS GSTR-9 & 9C
INTRODUCTION
ICAI is a statutory body established by an Act of Parliament, viz. The Chartered Accountants Act, 1949 for regulation and development of the profession of Chartered Accountants in the country. The Institute, functions under the administrative control of the Ministry of Corporate Affairs, Government of India. It is the world’s largest professional body of Chartered Accountants, committed to serving the Indian economy in the public interest.
The GST & Indirect Taxes Committee (GST & IDTC) of ICAI actively supports the Government in GST policy formulation and implementation by providing technical inputs and conducting various capacity-building initiatives. The Committee also plays a key role in enhancing GST awareness among stakeholders through publications, certificate courses, newsletter, seminars, conferences and the like.
As part of this ongoing effort, the GST & Indirect Taxes Committee has carefully reviewed the structure, format, and implementation challenges associated with Form GSTR-9 and Form GSTR-9C. These forms are integral to the annual compliance framework under GST, and accurate reporting in them is critical for taxpayers and regulators alike. The GST & Indirect Taxes Committee is pleased to present its suggestions on Form GSTR-9 and GSTR-9C to simplify the return filing and ensuring standardization, and clarity.
SUGGESTIONS ON ANNUAL RETURN
[FORM GSTR 9]
1. Exempted Supplies
Table 5D- Details of Exempted supplies made during the financial year.
Issue
Table 5D captures all exempted supplies in a consolidated manner. However, taxpayers frequently encounter practical issues where certain incomes such as interest income, though exempt under GST, are excluded from the exempt turnover while computing common ITC reversals.
Suggestion
Table 5D be divided into two parts as under:
| Table 5D | Exempted |
| Table 5D1 | Exempted Supplies for which reversal is not required (Not part of 5D above) |
Justification
This bifurcation will facilitate the precise identification of supplies relevant for reversal computations thereby avoiding overstatement of exempt turnover.
2. Table 5F – Non-GST Supply (includes ‘no supply‘)
Issue
Table 5F requires taxpayers to report Non-GST supplies, including what is referred to as ‘no supply’. A clarification issued through the press release dated 3rd July 2019 stated that “for the purposes of reporting, non-GST supplies include supply of alcoholic liquor for human consumption, motor spirit (commonly known as petrol), high-speed diesel, aviation turbine fuel, petroleum crude, natural gas, and transactions specified in Schedule III of the CGST Act.”
However, this requirement has led to confusion, particularly regarding the scope of disclosures required under Schedule III of the CGST Act, 2017. The key ambiguity lies in whether all activities listed under Schedule III need to be reported in this table or whether only select activities are to be included. This broad interpretation implies that even transactions such as salaries paid to employees may need to be reported in Table 5F, despite having no bearing on input tax credit (ITC) or GST turnover.
From a credit perspective, only the sale of land/building and supply of warehoused goods before clearance for home consumption are considered exempt supplies for the purpose of ITC reversal under Section 17(3) of the CGST Act, 2017.
Following the current interpretation results in overstated turnover figures in Form GSTR-9. More importantly, it affects the calculation of late fees under section 47(2) of the CGST Act, 2017, which imposes a penalty of ₹ 100 per day, subject to a maximum of 0.25% of the taxpayer’s turnover in the State or Union Territory.
As per Section 2(112) of the CGST Act, “turnover in the State” is defined to include:
“…the aggregate value of all taxable supplies (excluding inward supplies on which tax is payable under reverse charge), exempt supplies, exports, and inter-State supplies made from the State… but excludes central tax, State tax, UT tax, integrated tax, and cess.“
This definition does not include Schedule III transactions such as salary, court services, etc., which are outside the scope of GST. However, since Form GSTR-9 is often the only source from which the turnover value is derived for automated late fee calculation, taxpayers reporting Schedule III items in Table 5F may face inflated late fees, contrary to the intent of the law.
Suggestion
The Instructions be appropriately amended to clearly specify the reporting requirements under Table 5F, specifically in relation to Schedule III ‘no supply’ transactions.
Additionally, the methodology used by the GST portal for calculating late fees for delayed filing of Form GSTR-9 be reviewed and aligned with the definition of “turnover in the State” under Section 2(112) of the CGST Act. The inclusion of Schedule III values in turnover for the purpose of computing late fees be discontinued to avoid legal inconsistencies.
3. ITC reclaimed and any other ITC & Reconciliation – Tables 6 & 8
Issue
Currently, Table 6A of Form GSTR-9 auto-populates Input tax credit (ITC) data from Table 4A of Form GSTR-3B. However, in cases where ITC is initially availed, subsequently reversed, and then reclaimed within the same financial year, the format of Table 4A (5) of GSTR-3B causes the same ITC to be captured twice—once at the time of original availment and again upon re-availment after reversal. This duplication gets auto-populated in Table 6A of Form GSTR-9, thereby overstating ITC.
If such claimed and reclaimed ITC is reported only once in Table 6H, it results in a mismatch in Table 6J (computed as Difference = I – A), since the total ITC reported in Table 6I does not reconcile with the ITC shown in Table 6A.
Conversely, if the claimed and reclaimed ITC are reported separately Table 6B and Table 6H respectively, it eliminates the difference in Table 6J but creates a discrepancy in Table 8D [Difference = A – (B + C)]. This occurs because Table 8B includes both Table 6B and 6H (i.e., ITC availed first time in Table 6B and ITC reclaimed in Table 6H), while Table 8A is auto-populated from Form GSTR-2B (where ITC availed for first time only is captured) and Table 8C captures ITC availed in the subsequent financial year.
This reporting results in overstatement of ITC in Table 8B, causing a reconciliation gap in Table 8D and potentially triggering system-generated mismatch notices, despite there being no actual inconsistency in the taxpayer’s books or returns.
Suggestion
To resolve these structural issues and ensure seamless reconciliation, both the ITC claimed and reclaimed be declared in Table 6 and Table 6H be delinked from Table 8D. This can be achieved by way of the following amendments:
- Amendment in Instruction of Table 6B
“This shall not include ITC which was availed, reversed and then reclaimed in the ITC ledger. This is to be declared separately under 6(H) below.”
The above statement in Instruction of 6B be amended as under:
“In case of ITC availed, reversed and then reclaimed, ITC against the inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) which was availed (for the first time) should be declared in this table. ITC which was reversed should be declared in Table 7 and ITC that is reclaimed should only be declared in Table 6H.”
- Amendments in Table 6H
Words “other than B above” be removed from Table 6H as under:
| Table 6H | Amount of ITC reclaimed under the provisions of the Act |
Further, Table 6H be linked with Table 4(d)(1) of Form GSTR 3B for reducing the manual entry.
- Amendment in Table 8B
| Table 8B | ITC as per 6(B) above |
Consequential amendment be made in the Instruction of Table 8B by removing reference of Table 6H.
Justification
Declaring claimed and reclaimed ITC separately and removing the linkage of Table 6H from Table 8B will remove duplication differences in Table 6J and/or Table 8D. This change will help reflect a more accurate position of credit utilization by ensuring that ITC initially claimed is reported in Table 6B, any subsequent reversal is disclosed in Table 7A or 7H, and the re-availment of such credit is appropriately captured in Table 6H.
Moreover, updating the Instruction to Table 6B will help taxpayers distinguish clearly between initial availment and subsequent reclaim of ITC. Linking Table 6H with Table 4D (1) of Form GSTR-3B will further enhance the accuracy of reporting by reducing manual intervention and enabling a system-driven validation of reclaimed credit.
Collectively, these changes will ensure that ITC claimed, reversed and reclaimed is accurately categorized as inputs, input services, or capital goods, and help eliminate artificial differences in Table 6J or Table 8D that arise purely due to structural issues in Form GSTR-3B.
4. Table 7H – Other reversals
Issue
There is no separate field in Table 7 for reporting temporary ITC reversals other than reversals on account of Rule 37. Further, Instructions for Table 7H-Other reversals, mandate that only ITC reversed through Form ITC-03 should be declared therein, thus leaving no place for such other temporary reversals.
Suggestion
The Instructions be amended to clarify that any temporary reversal (other than reversal under rule 37) made in Table 4(B)(2) of Form GSTR-3B, be also reported in Table 7H. An illustrative list of reversals may be given for clarity e.g., ITC reversed through Form ITC-03, ITC reversal due to non-payment of tax by the supplier or any non-compliance of condition under section 16(2) of the CGST Act, 2017.
5. Incorrect Reflection of Unclaimed IGST on Imports as Lapsed Credit in Table 8G to 8K
Issue
Tables 8G to 8K treat un-availed IGST credit on import of goods as lapsed, without considering scenarios where the taxpayer subsequently avails the credit in the next financial year.
Suggestion
Table 8H be divided into two parts as under-
| Table 8H | IGST Credit availed on Import of goods (as per 6(E) above) |
| Table 8H1 | IGST Credit on Imports Received during the Financial Year but Availed in the Next Financial Year. |
Simultaneously Table 8I be also amended as under:
| Table 8I | Difference [G- (H + H1] |
Justification
This bifurcation will separately capture IGST credit on import of goods that is availed in the next financial year. Like the way Table 8C allows disclosure of regular ITC availed in the subsequent year, this bifurcation will enable accurate reporting of carried forward IGST credit on imported goods preventing the misclassification of eligible credit as lapsed credit.
6. Paragraph 9 of the Instructions to Form GSTR-9: Additional liability – To be paid through cash
Issue
Para 9 of Instructions of Form GSTR-9 mandates that the additional liability declared therein can be paid only through cash ledger. It may be noted that there is no such restriction in the GST law; even the demands confirmed vide orders issued under section 73 of the CGST Act, 2017 can be paid by utilising credit. However, Para 9 does not allow the same.
Suggestion
The Instruction be amended to allow the taxpayer to pay the additional liability using credit. This would also be in line with the provisions of GST law.
7. Table 10 – Supplies pertaining to the reporting financial year but disclosed in the returns of the subsequent financial year
Part V
Issue
Taxpayers face considerable confusion while reporting transactions in Form GSTR-9, particularly in cases where transactions involve two financial years i.e., where the event or supply pertains to one financial year but is reflected in the returns of the subsequent year.
Owing to Instruction 2A of Form GSTR-9, a taxable supply pertaining to a given financial year, even if reported in the returns of a subsequent financial year, is required to be disclosed in Table 4 of Form GSTR-9 for the financial year to which the supply relates. Since the figures of tax paid in Table 9 are auto-populated from Table 6.1 of Form GSTR-3B, this results in a mismatch between the tax payable and the tax paid reported in Table 9. The discrepancy arises because the tax payable includes liability on supplies disclosed in Table 4, whereas the corresponding tax paid (through cash / ITC) is not reflected, as it was made through Form GSTR-3B filed in the subsequent financial year.
It is pertinent to note that Para E of the Press Release dated 03.07.2019 provides that any additional outward supply not declared in Form GSTR-1 and Form GSTR-3B may be disclosed in Part II of Form GSTR-9 of the relevant financial year, and the corresponding tax liability should be disclosed in Part IV and discharged through Form DRC-03. Furthermore, Para 4 of the Instructions to Form GSTR-9 reiterates that additional liability for the financial year, not declared in Form GSTR-1 and GSTR-3B, may be reported in Form GSTR-9. Since neither the Press Release nor the Instructions explicitly require that such omissions pertain specifically to Form GSTR-1 and Form GSTR-3B of the same financial year, it can be reasonably inferred that these provisions are intended to cover only those supplies on which tax has not been paid at all, and not those supplies that have been reported in the subsequent financial year.
Moreover, the said supply cannot be disclosed in Part V of Form GSTR-9 either, as that part permits reporting only of amendments and debit/credit notes, and not original invoices.
Another issue with Instruction 2A is that it specifies that in Tables 4, 5, 6 and 7, values pertaining to the financial year only should be reported and not the value pertaining to the preceding financial year. While this may be followed for Tables 4 & 5, the same cannot be followed in Tables 6 & 7 where ITC is to be matched with figures reported in Form GSTR-3B and Form GSTR-2B. In these Tables, details of ITC pertaining to previous financial years which is reclaimed/reversed in the reporting financial year are to be declared to arrive at the net ITC available for utilization during the financial year.
It may be noted that in terms of GSTN advisory issued on 9th December 2024, if an invoice pertains to the financial year 2023-24 and ITC was initially claimed in that year but subsequently reversed due to non-payment within 180 days, and the ITC is later reclaimed in FY 2024-25 after payment is made to the supplier, the reclaimed ITC must be reported in Table 6H of GSTR-9 for FY 2024-25. Thus, here also the advisory requires reporting of ITC details of previous years which contradicts Instruction 2A.
Suggestions
(i) Table 10 of Part V be amended as under:
| 10 | Supplies/tax declared through original invoice, Amendments (+) (net of debit notes) |
The above amendment will ensure that the mismatch in Table 9 on account of a supply reported in subsequent financial year is reconciled through Table 10 and consequential computation of tax in Table 14.
(ii) Instruction 2A be amended to remove the reference of Tables 6 & 7 therefrom. This will align the Instruction with the reporting requirements of Tables 6 & 7.
8. Table 10 & 11 – Debit/Credit Notes Issued in the Subsequent Financial Year against Invoices pertaining to the Reporting Financial Year
Issue
The issue is explained with the help of an example given below –
A debit note is issued in June 2024 against an invoice raised in FY 2023-24. If the same is considered as pertaining to FY 2023-24, then based on Para J of the Press Release dated 03.07.2019, such debit note can be reported in Part V of the Annual Return only if a provision was made in the books of accounts of the reporting year (i.e., FY 2023-24).
However, many listed and large entities are required to finalize and submit audited financial statements within 60 days of the financial year end, i.e., by May. Hence, any debit or credit notes issued after May would generally not have any provision in the financials of the reporting year, effectively disqualifying them from being reported in Form GSTR-9 of the FY 2023-24.
The said debit note cannot be reported in Form GSTR-9 for FY2024-25 as well due to the restriction laid down in Para 2A of the Instructions, which prohibits inclusion of values pertaining to the preceding financial year.
As a result, the debit note becomes unreportable in both financial years, despite having tax implications.
A similar problem arises in case of credit notes issued/ upward or downward amendments made, in the subsequent financial year against invoices pertaining to the reporting financial year.
Suggestion
The Instructions to Tables 10 & 11 be appropriately amended to clarify the reporting requirements of debit/credit notes issued in the subsequent financial year against invoices pertaining to the reporting financial year.
9. Tables 12 & 13 – Nomenclature needs amendment
Issue
The reference of word ‘previous’ in Tables 12 & 13 creates confusion as the Heading of Part V clearly specifies that “Particulars of the transactions for the financial year declared in returns of the next financial year till the specified period” are to be filled in Tables 10, 11, 12, 13 and 14.
Suggestion
Tables 12 & 13 be re-worded as under to bring clarity and to ensure consistency in the usage of the term financial year across the Form GSTR-9:
| 12 | Reversal of ITC availed during financial year |
| 13 | ITC availed for the financial year |
10. Table 17-HSN Wise Summary of outward supplies
Issue
Currently, the HSN summary in GSTR-9 requires manual entry, which is time-consuming and increases the risk of clerical errors
Suggestion
It is suggested that the HSN summary in Form GSTR-9 be auto-populated based on GSTR-1 data, with an option for taxpayers to edit the entries if required. This enhancement will reduce manual effort, improve reporting accuracy, and streamline the compliance process.
SUGGESTIONS ON RECONCILIATION
STATEMENT [FORM GSTR-9C]
1. Adjustments in Turnover
Suggestion
Table 5O be enhanced with an editable sub-table, triggered via an ‘Add’ radio button (‘+’ sign) to allow taxpayers to report adjustments individually. This will improve transparency and ensure clarity for taxpayers as well as departmental authorities.
Upon clicking the button, a new row should appear within a sub-table where taxpayers can provide item-wise bifurcation of the adjustments being reported. This would allow users to specify each item/adjustment separately with relevant descriptions and values. Such a feature will ensure better traceability, promote accurate reporting, and reduce queries or disputes arising due to lack of clarity in cumulative reporting.
An illustrative list of adjustments is given hereunder:
| 5O | Adjustments in Turnover due to reasons not listed | (+/-) | Sum |
| 5O1 | Difference in P/L Revenue as per AS/IND AS related to revenue recognition and as per GST law | ||
| 5O2 | Expenses netted off from Revenue, while reporting in financials | ||
| 5O3 | Profit/Loss on sales of assets as per companies act | ||
| 5O4 | Taxable value of assets on which GST Payable | ||
| 5O5 | Rounding value of turnover | ||
| (Click ‘+’ to add a new row for additional item-wise adjustments if any) |
2. Supplies made through E-Commerce Operator (ECO) tax on which is payable by ECO under section 9(5) of the CGST Act, 2017
Issue
In the year 2023-24, Form GSTR-9 was amended to include two new rows in Tables 4 and 5 as under:
- 4G1 for Supplies on which e-commerce operator is required to pay tax as per section 9(5) (including amendments, if any) [E-commerce operator to report], and
- 5C1 for Supplies on which tax is to be paid by e-commerce operators as per section 9(5) [Supplier to report].
However, no corresponding changes were made in Form GSTR-9C, particularly in Table 7, which captures the reconciliation of Taxable Turnover. This has resulted in unintended mismatches between Form GSTR-9 and Form GSTR-9C, both for suppliers who supply through e-commerce operators and for the e-commerce operators themselves.
Suggestion
Parallel amendments be incorporated in Form GSTR-9C as under:
- A new row ‘D1’ be inserted after row ‘D’ in Table 7 as under
| D1 | Supplies on which tax is to be paid by e-commerce operators as per section 9(5) [Supplier to report] |
- Simultaneously Table 7E be also amended as under:
| E | Taxable turnover as per adjustment above (A-B-C-D-D1) |
- The Instruction of Table 7F be revised as under-
“Taxable turnover as declared in Table [4N – (4G + 4G1) + (10 – 11)] of the Annual Return (Form GSTR-9) shall be declared here.”
- A new row ‘K 2’ be inserted in Table 9 to separately report the tax paid by e-commerce operators under section 9(5) on behalf of suppliers, as under:
| Description | Taxable Value | Central tax |
State tax / UT tax |
Integrated Tax | Cess, if applica ble | |
| K 2 | Tax paid by ECO under section 9(5) [ECO to report] | NA | – | – | – |
Justification
The above amendments will ensure that both forms are aligned with the recent structural changes introduced to account for section 9(5) supplies and will eliminate the discrepancies in reconciliation.
3. Inclusion of Interest Payable/Paid in Table 9Q
Issue
Table 9Q auto-populates the details of tax paid as declared in Table 9 of Form GSTR 9 including any differential tax paid as disclosed in Table 10 or 11 of Form GSTR-9. However, the Table does not capture the Interest, Late fee & Penalty, due to inconsistency between the formats of Form GSTR-9 and Form GSTR-9C. This results in a mismatch with the disclosures made in Table 9R, where interest, late fee & penalty payment details are reported.
Suggestion
To ensure accurate and complete reporting, it is suggested that suitable modifications be made in the format of Form GSTR-9 or Form GSTR-9C so that Table 9Q either captures the interest, late fee & penalty amount from Form GSTR-9 or excludes the same for reconciliation purposes.
4. Modification of Table 11 to Include ITC Utilization
Issue
Table 11 captures only tax payments to be made in cash. Since taxpayers primarily utilize ITC before making cash payments, this limitation results in incomplete reconciliation.
Suggestion
It is recommended that Table 11 be modified to include a separate disclosure for tax paid through ITC to ensure accurate reconciliation of tax payments. A structured disclosure of ITC utilization alongside cash payments will enhance transparency, improve compliance accuracy, and align tax reporting with actual payment practices.
