🧾 Detailed Analysis of GSTR-9 and GSTR-9C Changes for FY 2024-25
Effective from: 22 September 2025 Applicable for: Annual Return & Reconciliation Statement of FY 2024-25 Issued by: CBIC (Central Board of Indirect Taxes & Customs)
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📘 1. Background
Every registered taxpayer (except those exempted) must file GSTR-9 (Annual Return) and, where turnover exceeds ₹5 crore, GSTR-9C (Reconciliation Statement) each year.
In September 2025, the CBIC introduced major structural and disclosure changes to these forms to strengthen ITC monitoring and reduce mismatches between GST returns and books of accounts.
Objective of the changes:
· Enhance Input Tax Credit (ITC) visibility
· Improve data reconciliation and system-based checks
· Increase auditor accountability for mismatches
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🧩 2. Major Changes in GSTR-9 (Annual Return)
The most important revisions have been made in Table 6, which covers ITC details.
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🔹 a. Table 6A Split into Two Sub-Tables – 6A1 & 6A2
Sub-Table Description Example
6A1 – ITC of
preceding FY availed
in current FY Discloses ITC related to invoices of previous FY (e.g., FY 2023-24) but claimed between April–November 2024. Invoice dated Feb 2024, ITC claimed in April 2024.
6A2 – ITC of current
FY Reflects ITC pertaining only to FY 2024-25. Invoice dated June 2024, ITC claimed in same FY.
💡 Purpose: This split helps the department track delayed ITC claims and check compliance with Section 16(4).
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🔹 b. Rule-Wise ITC Reversal Disclosure (Tables 6J–6L Expanded)
Earlier, reversals were reported in a single figure. Now, taxpayers must provide rule-wise breakup.
Rule Description Example
Rule 37 Reversal if supplier not paid within 180 days Invoice unpaid beyond 180 days.
Rule 37A Reverse charge / supplier non-payment case Supplier files late; buyer reverses temporarily.
Rule 38 ISD reversals Credit distributed incorrectly by head office.
Rule 42 /
43 Common credit for exempt & taxable supplies Inputs used for both taxable and exempt purposes.
🧾 Impact: Taxpayers must maintain detailed ITC reversal registers, categorized by rule. This also enables system-based validations with GSTR-3B data.
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🔹 c. Table 6M – Expanded for ITC Transfers (ITC-01 / 02 / 02A)
New inclusions:
· ITC-01 – Credit on new or voluntary registration
· ITC-02 / 02A – ITC transfer due to merger, demerger, or business transfer
📘 Purpose: Ensures traceability of credits resulting from reorganizations and ownership changes.
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🔹 d. Table 8 – ITC Reconciliation Shifted to GSTR-2B
Earlier Now
Based on GSTR-2A (dynamic data) Based on GSTR-2B (static data)
✅ Benefit: Eliminates confusion from late supplier filings and aligns ITC eligibility with the legal base document (2B).
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🔹 e. Optional Tables Now Mostly Mandatory
Tables 15 (Demands & Refunds), 16 (Supplies from composition taxpayers), and 17 (HSN summary) are no longer optional unless data is genuinely Nil.
🎯 Purpose: To ensure data completeness and curb under-reporting.
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📊 3. Major Changes in GSTR-9C (Reconciliation Statement)
The reconciliation statement is now stricter and more data-driven.
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🔹 a. ITC Reconciliation (Tables 12A–12C) Now Mandatory
Table Description Change
12A ITC as per books Must be filled mandatorily
12B ITC as per GSTR-9 Auto-populated but must be verified
12C Reasons for differences Auditor/taxpayer must explain variances
📍 Example: If books show ITC ₹12,00,000 but GSTR-9 shows ₹11,80,000, difference of ₹20,000 must be explained (e.g., reversal under Rule 42).
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🔹 b. Cross-Linking Between GSTR-9 and GSTR-9C
Figures of reversals (6J–6L) in GSTR-9 must match the ITC reconciliation figures in GSTR-9C. This eliminates inconsistencies between the taxpayer’s return and audit report.
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🔹 c. Revised Verification Text
The verification statement has been modified to meet digital verification standards and highlight auditor’s responsibility for correctness of ITC reconciliations.
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💡 4. Key Compliance Implications
✅ ITC Tracking: Maintain year-wise ITC registers (Current FY vs. Previous FY claimed later).
✅ Rule-Wise Reversal Register: Track reversals under Rules 37, 37A, 42, 43 individually.
✅ Quarterly Reconciliation: Match GSTR-3B, GSTR-1, and GSTR-2B quarterly instead of year-end.
✅ Auditor Preparedness: Ensure complete documentation of ITC variances and reversal reasons.
✅ Software Upgrades: Update accounting/GST tools to handle new tables and validations.
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🧮 5. Practical Example
Particulars Earlier (FY 2023-24) Now (FY 2024-25)
ITC of previous FY claimed in Apr
2024 Included in total ITC Must be shown in Table 6A1
ITC reversal for non-payment Shown in total Report under Rule 37
ITC for exempt supplies Combined Report separately under Rule 42
ITC due to merger Clubbed in “Others” Report in Table 6M (ITC-02)
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📅 6. Due Dates and Applicability
Form Applicability Due Date Filing Mode
GSTR-9 Regular taxpayers with turnover > ₹2 crore 31 December 2025 Online via GST Portal
GSTR-
9C Taxpayers with turnover > ₹5 crore 31 December 2025 Self-certified (CA audit only if required by state law)
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✅ 7. Preparation Checklist
· Maintain separate registers for current and prior year ITC
· Record rule-wise reversals and reclaims
· Reconcile ITC as per books vs. GSTR-2B monthly
· Document reasons for mismatches (for Table 12C)
· Update ERP/GST software for new form structures
· Verify supplier GSTR-1 filing status regularly
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🧭 8. Conclusion
The revised GSTR-9 and GSTR-9C formats mark a major step toward transparency and system-driven GST compliance. While it adds to reporting effort, it helps businesses maintain cleaner ITC records, minimize audit disputes, and ensure accurate reconciliations.
Early preparation, quarterly reconciliation, and close coordination with auditors will ensure smooth filing before 31 December 2025.
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