GSTR-9 and 9C for FY 2024-25: optional versus mandatory, and the 31 December 2026 window

The GSTR-9 architecture in 2026

GSTR-9 is the annual return that consolidates the monthly or quarterly GSTR-1 and GSTR-3B filings of a registered person for a financial year. The form was introduced under Section 44 of the CGST Act, 2017 and has been in force since FY 2017-18. The current 19-table structure has been stable since FY 2021-22, with minor tweaks each year through notification.

For FY 2024-25 the filing window closes on 31 December 2026 unless the CBIC extends the deadline. GSTR-9C, the reconciliation statement, sits alongside GSTR-9 and has been self-certified by the taxpayer since the Finance Act 2021 omitted Section 35(5) of the CGST Act and dropped the CA or CMA audit certification requirement.

The optional versus mandatory split

GSTR-9 is optional for taxpayers with aggregate turnover up to ₹2 crore, and mandatory above. The ₹2 crore threshold was last revised by Notification 14/2024-Central Tax dated 10 July 2024 and has been retained for FY 2024-25. The "aggregate turnover" computation is at the PAN level, not the GSTIN level, so a taxpayer registered in multiple states aggregates turnover across all GSTINs.

GSTR-9C is mandatory above ₹5 crore aggregate turnover. The 9C is a reconciliation between the GSTR-9 figures and the audited annual financial statements at the PAN level. The form captures any differences and asks the taxpayer to certify the reconciliation.

The implication for compliance planning: every GSTIN in a multi-state taxpayer with PAN-level turnover above ₹5 crore must file 9C; every GSTIN in a multi-state taxpayer with PAN-level turnover above ₹2 crore must file 9. A small-state branch of a national chain does not escape the filing just because its individual GSTIN turnover is below the threshold.

Why the ₹2 crore "optional" is rarely optional

The Department's automated scrutiny module now picks up taxpayers above ₹1.5 crore turnover who have not filed GSTR-9 voluntarily, runs a turnover-versus-GSTR-3B comparison, and issues an ASMT-10 notice if mismatches exceed 5 percent. The notice asks for a reconciliation in 30 days. The reconciliation is, in substance, the same exercise as preparing GSTR-9.

The practical KAMRIT view: any GSTIN above ₹1.5 crore turnover should prepare GSTR-9 internally even if voluntary filing is skipped, because the reconciliation will be needed when the ASMT-10 arrives. Below ₹1.5 crore, the cost-benefit usually does not justify the exercise.

Table-by-table reconciliation: the seven critical tables

GSTR-9 has 19 tables. Seven of them carry almost all the audit risk.

Table 4: Outward supplies on which tax is payable. Reconcile to GSTR-1 outward supplies, less credit notes, plus any unrecorded transactions. Common error: invoices reported in the wrong tax rate (5 percent versus 12 percent) and not corrected via GSTR-1A or amendment.

Table 5: Outward supplies on which tax is not payable. Exempt, nil-rated, and non-GST supplies. Reconcile to revenue ledger. Common error: zero-rated exports (Table 5A) booked as taxable supplies in GSTR-1, requiring amendment.

Table 6: ITC availed during the FY. Reconcile to GSTR-3B ITC claimed, with sub-categorisation by capital goods, input services, RCM, and import. This is the table the Department scrutinises most heavily.

Table 8: ITC reconciliation. Compares Table 6 (ITC availed in GSTR-3B) to Table 8A (ITC auto-populated from GSTR-2A) plus Table 8C (ITC of FY 2023-24 availed in FY 2024-25). The "Table 8D" residual figure is the difference, and any positive figure here triggers a query.

Table 9: Tax paid as declared in GSTR-3B. Reconcile to GSTR-3B liability ledger and cash + credit ledger debits. Common error: RCM liability paid in cash but not declared correctly in this table.

Tables 17 and 18: HSN-wise summary of inward and outward supplies. Required for taxpayers above ₹5 crore turnover at 6-digit HSN level, and above ₹1.5 crore at 4-digit. Common error: HSN summary in GSTR-1 not aligned with GSTR-9, leading to an automatic flag.

The Section 16(4) timing trap

Section 16(4) of the CGST Act sets the outer limit for claiming ITC: by the 30 November following the end of the FY, or by the date of filing the annual return, whichever is earlier. For FY 2024-25, ITC could be claimed up to 30 November 2025 in the October 2025 GSTR-3B.

GSTR-9 Table 13 captures the ITC of the previous FY availed in the current FY (FY 2023-24 ITC availed in FY 2024-25), and Table 8C captures the ITC of the current FY availed in subsequent months of the current FY (FY 2024-25 ITC availed in April-October 2025 GSTR-3B). The reconciliation between Tables 8C and 13 is one of the most-queried areas in GSTR-9 scrutiny.

RCM and the imported services trap

Reverse charge mechanism liability under Section 9(3) and 9(4) is declared in GSTR-3B Table 3.1(d) and paid in cash. The same liability flows into GSTR-9 Table 4G. A common error is to declare RCM liability in GSTR-3B but to skip the corresponding ITC (claimable in Table 6C of GSTR-9). The result is double-payment: RCM in cash, plus a corresponding ITC not availed.

Imported services attract RCM under Section 9(3) read with Notification 10/2017-IGST. Software subscriptions to Microsoft Azure, AWS, Google Workspace, Slack, and similar global vendors generate ongoing RCM liability for Indian buyers. Where the buyer has missed the RCM declaration in GSTR-3B, the position must be corrected in GSTR-9 Table 4G with the corresponding ITC in Table 6C. Interest under Section 50 applies from the due date of GSTR-3B to the date of payment.

GSTR-9C: what the self-certification actually covers

GSTR-9C is a reconciliation between three numbers: the turnover per audited financials, the turnover per GSTR-9, and the tax liability per GSTR-9 versus tax liability per audited financials. The differences are captured table by table.

The self-certification by the taxpayer (since FY 2020-21) replaced the earlier CA or CMA audit certification. The taxpayer's authorised signatory certifies that the reconciliation is correct, that any differences are explained, and that the additional tax liability (if any) has been paid through DRC-03.

Common 9C reconciliation items: revenue recognised under Ind AS 115 versus invoice-date GST liability (timing difference for SaaS subscriptions, EPC contracts), bad debts written off (no GST adjustment unless the supply was cancelled), branch transfers (intra-PAN, no GST in audited financials but GST liability in GSTR-9 if inter-state).

The 31 December 2026 cliff and the late fee

The late fee for GSTR-9 is ₹100 per day under CGST and ₹100 per day under SGST (₹200 per day total). The cap is 0.04 percent of turnover in the state. For a ₹50 crore turnover GSTIN in one state, the cap is ₹2 lakh. The cap is reached at approximately 1,000 days of delay.

GSTR-9C late filing attracts a separate, discretionary penalty under Section 125 of up to ₹25,000. There is no per-day fee for 9C, but the penalty under 125 is regularly invoked where 9C is filed more than 6 months late.

The CBIC has historically extended the GSTR-9 deadline by 1 to 2 months. For FY 2023-24, the deadline was extended to 31 March 2025 by Notification 12/2024-CT. KAMRIT's planning assumption is that no extension will be granted for FY 2024-25, so the 31 December 2026 date should be treated as final.

How KAMRIT runs the annual return engagement

KAMRIT's GST desk runs GSTR-9 and 9C as a 21-day engagement starting from a clean books cut-off date. Week 1 is data extraction and reconciliation between books, GSTR-1, GSTR-3B, and GSTR-2A/2B. Week 2 is table-by-table population of GSTR-9 and 9C, with a written reconciliation memo for every Table 8D variance, every Section 16(4) timing item, and every RCM exposure. Week 3 is internal review, authorised-signatory walkthrough, and filing.

Comparable platform options include ClearTax GST and IRIS GST for the form filling, with CAclubindia carrying the editorial commentary on table-wise nuances. The KAMRIT positioning is on the reconciliation memo and the ASMT-10 defence pack that the annual return engagement produces as a by-product.

If your business has turnover above ₹2 crore for FY 2024-25, the GSTR-9 clock is now ticking on the 31 December 2026 deadline. Talk to KAMRIT to scope the engagement before the September quarter. Senior associate from the GST desk handles the full reconciliation, the table population, and the 9C self-certification pack. Fixed fee from ₹35,000 per GSTIN for the standard 9-only engagement and ₹65,000 for the 9 plus 9C pack. Send a brief to the GST Returns page or start a conversation with a senior partner.