Important Changes in GSTR-9 for FY 2024-25 You Must Prepare For

For FY 2024–25, GSTR-9 and GSTR-9C have been notified with certain earlier relaxations continuing, such as consolidated reporting of exempt and nil-rated supplies, optional ITC bifurcation in some cases, simplified RCM reporting, and optional disclosure of refund, inward supply, and HSN-inward details. However, significant changes introduce additional reconciliation challenges. A new Table 6A1 requires disclosure of ITC pertaining to FY 2023–24 but availed in FY 2024–25, which was not captured in previous year’s Tables 8C or 13, creating complexity in deriving net ITC at Table 6A2. Table 8A has also been revised to include invoices dated FY 2024–25 uploaded in both FY 2024–25 and FY 2025–26, while excluding FY 2023–24 invoices uploaded late, requiring deeper reconciliation with Table 6B. Positive and negative differences must be reported across Tables 8C, 12, and 13, effectively reintroducing a GSTR-2A, GSTR-2B, and GSTR-3B-style matching similar to FY 2022–23.

Observation on GSTR 9 for the FY 2024-25:

GSTR 9 and GSTR 9C as applicable for the FY 2024-25 were notified vide Notification No. 13/2025– CT dated 17-Sep-2025 through CGST (Third Amendment) Rules, 2025. Some of the relaxations as provided till FY 2023-24 were continued for the FY 2024-25 as well, these are as under:

Relaxations as applicable for the FY 2024-25 in respect of GSTR 9:

Relaxations as applicable for the FY 2024-25 in respect of GSTR 9C:

Table 14 – Expense head wise details of ITC claimed.

Major Changes in GSTR 9 as applicable for the FY 2024-25 requiring additional efforts:

1. Table 6A1 – ITC of FY 2023-24 availed in FY 2024-25

Table 6 requires us to give break-up of ITC availed in GSTR 3B of FY 2024-25 into ‘Inputs, ‘Input Service’ and ‘Capital Goods.

Table 6A contains the information about Gross ITC claimed in GSTR 3B filed for the FY 2024-25, wherein ITC was claimed based on GSTR 2B as available for the respective period of FY 2024-25.

New line added as 6A1 requiring us to give the information of ITC of FY 2023-24 availed in FY 2024-25 which will get reduced from 6A and net ITC of FY 2024-25 availed in FY 2024-25 will be calculated at 6A2, here the issue is that such ITC was not disclosed in Table 8C and Table 13 GSTR 9 of FY 2023-24 as it was not forming part of Table 8A of GSTR 9 for the FY 2023-24. Net ITC appearing in Table 6A2 will then be reconciled with Table 8A.

Accordingly, break up of net ITC as appearing in 6A2 is to be given between ‘Inputs’, ‘Input Service’ and ‘Capital Goods’ (relaxation is available as mentioned in the above table), so that there will be no difference at the end of Table 6.

2. Table 8A – ITC as per GSTR 2B

Though heading of table suggests that it is GSTR 2B which is available every month for claiming ITC, however it also contains the Invoices/DNs/CNs dated FY 2024-25 uploaded by the suppliers in the FY 2025-26.

But it will not include the invoices dated FY 2023-24 uploaded by the suppliers in the FY 2024-25 that means Invoices/DNs/CNs dated FY 2023-24 uploaded in the FY 2024-25 were neither forming part of Table 8A of FY 2023-24 nor forming part of Table 8A of FY 2024-25 leading to additional reconciliation, though this information is reduced in Table 6A1.

Table 8A will have two information:

• Invoices/DNs/CNs dated FY 2024-25 uploaded during FY 2024-25;
• Invoices/DNs/CNs dated FY 2024-25 uploaded during FY 2025-26 up to the allowed time limit;

Table 8B will capture the information from Table 6B, difference between Table 8A and Table 8B will be on account of the following:

• Invoices/DNs/CNs dated FY 2024-25 uploaded during FY 2025-26 up to the allowed time limit;

After due reconciliation such difference is required to be bifurcated between Invoices+DNs of FY 2024-25 claimed in FY 2025-26 (positive difference) and CNs of FY 2024-25 claimed in FY 2025-26 (negative difference).

Additional disclosure such positive and negative difference should also be given in Table 12 –  “ITC of the FY reversed in the next FY” and Table 13 – “ITC of the FY availed in the next FY”.

Table 8C accepts negative value

Further Table 8C accepts negative value, which will be required in cases where CN dated FY 2024-25 uploaded by the supplier in FY 2025-26 as it will form part of Table 8A, the same will also have to be disclosed in Table 12 of GSTR 9 in case ITC claimed based on GSTR 2B during the FY 2025-26, though the heading of Table 12 doesn’t match with the nature of difference arising on account of CNs.

Given the current scenario and department’s stand that any ITC of previous year claimed in subsequent year but not disclosed in Table 8C and/or in Table 13 of GSTR 9 of the previous year is required to be reversed.

The above information is taking us back to FY 2022-23 era wherein we were required to reconcile GSTR 2A vs GSTR 2B vs GSTR 3B.

Till FY 2022-23 Table 8A was based on GSTR 2A (volatile in nature) and accordingly department changed Table 8A information to GSTR 2B for the FY 2023-24 leading to less reconciliation items and again in FY 2024-25 they changed Table 8A to GSTR 2A.

Further in many cases updated Table 8A information will be made available as on 01^st December, 2025 as the timeline for uploading the Invoices/DNs/CNs dated FY 2024-25 is 30^th November, 2025 giving time of 1 month to prepare and file GSTR 9 and GSTR 9C.