Introduction
The filing of GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement and Certification) for the Financial Year 2024-25 represents a crucial statutory responsibility for all regular taxpayers under the Goods and Services Tax framework.
With this year introducing refined ITC disclosures, enhanced data validations, and strengthened reconciliation requirements, businesses must ensure strict compliance.
As practising Chartered Accountants, we ensure that every figure reported—from turnover to ITC—is accurate, audit-ready, and fully aligned with the CGST Act, GST Rules, and ICAI Standards on Auditing.
📅 Statutory Due Date for Filing GSTR-9 & GSTR-9C (FY 2024-25)
➡ The last date for filing GSTR-9 and GSTR-9C for FY 2024-25 is 31st December 2025
(unless extended by a subsequent Government notification).
Given the extensive reconciliation and documentation required this year, early preparation is strongly advisable.
1. Understanding GSTR-9 for FY 2024-25
GSTR-9 is the Annual Return that consolidates:
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GSTR-1
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GSTR-3B
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Books of accounts
It serves as a comprehensive statement of a taxpayer’s yearly GST compliance and is often used by GST authorities as an analytical tool to identify mismatches and potential risk areas.
Who Must File?
All regular GST taxpayers except:
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Composition dealers
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Casual taxable persons
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Non-resident taxable persons
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ISDs
Taxpayers with annual turnover up to ₹2 crore have optional filing, subject to applicable notifications.
2. Understanding GSTR-9C
GSTR-9C is mandatory for taxpayers with an aggregate turnover exceeding ₹5 crore during FY 2024-25.
It requires:
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A reconciliation between audited financials and GST returns
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Validation of ITC claims
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Verification of tax liabilities
3. Key Amendments for FY 2024-25
This year’s annual return introduces several significant updates:
3.1 New Table 6A1 – Cross-Year ITC Reporting
Discloses ITC of FY 2023-24 claimed during FY 2024-25.
This prevents distortion of year-specific ITC and strengthens audit trails.
3.2 Stronger Validation with GSTR-2B (Table 8A/8C)
Reconciliation between books and supplier data is now more critical.
Negative ITC is permitted in Table 8C due to year-end credit notes.
3.3 Auto-Inclusion of GSTR-1A and IFF Amendments
Outward supply amendments reported late are automatically reflected in GSTR-9.
3.4 Mandatory Reconciliation Strengthening
Turnover must now match across:
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Books
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GSTR-1
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GSTR-3B
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E-invoice
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E-way bills
Any deviation may attract scrutiny.
4. Detailed Table-Wise Analysis of GSTR-9
Table 4 & 5 – Outward Supplies
Includes taxable supplies, exempt supplies, non-GST supplies, and amendments.
Consistency between GSTR-1/GSTR-3B/books is essential.
Table 6 – ITC Reporting
The most sensitive section of the annual return.
6A – Total ITC (Auto-populated from GSTR-3B)
6A1 – ITC of previous FY claimed during FY 2024-25 (New Requirement)
6A2 – Net ITC pertaining to FY 2024-25
Professionally, ITC must be supported by:
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Vendor compliance
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GSTR-2B matching
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Eligible vs ineligible ITC classification
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Proper documentation
Table 7 – ITC Reversal
Disclosures required for:
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Rule 42/43
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Ineligible ITC (Section 17(5))
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180-day non-payment reversals
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RCM adjustments
Table 8 – ITC as per Supplier Records
8A – Auto-populated from GSTR-2B
8C – Differences (Positive or Negative)
Significant mismatches may result in notices or ITC disputes.
Table 9 – Tax Paid
Reconciliation between:
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Tax actually paid
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Liability reported
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Books
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GSTR-3B
is essential to avoid inconsistencies.
Table 12 & 13 – Year-End ITC Adjustments
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Table 12 → ITC reversed in FY 2025-26 relating to FY 2024-25
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Table 13 → ITC relating to FY 2024-25 availed in FY 2025-26
Table 17 – HSN Summary
Misclassification here can trigger tax rate disputes.
HSN accuracy is crucial for audit defence.
5. GSTR-9C – Reconciliation and Certification Framework
As practising Chartered Accountants, our process includes:
5.1 Turnover Reconciliation
Mapping turnover between:
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Financial statements
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GSTR-1
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GSTR-3B
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E-invoices
5.2 Tax Liability Verification
Ensuring:
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Correct classification
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RCM liabilities
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Rate applicability
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Amendments
5.3 ITC Validation
Checking:
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Eligible ITC
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Reversed ITC
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Cross-year ITC
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Supplier compliance
5.4 Certification
The CA certifies correctness and ensures compliance with:
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SA 700 / SA 705 / SA 706
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SA 500
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ICAI Ethical Standards
6. Professional Recommendations for Taxpayers
As Chartered Accountants, we advise the following:
✔ Begin reconciliation early
✔ Cross-verify ITC with GSTR-2B monthly
✔ Validate all vendor invoices before year-end
✔ Maintain a separate cross-year ITC register
✔ Ensure RCM compliance is complete
✔ Perform a year-end GST internal audit before filing GSTR-9
7. Common Errors to Avoid
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Not reporting cross-year ITC in Table 6A1
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Mismatch between books and GSTR-2B
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Incorrect HSN classification
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Under-reporting or over-reporting turnover
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Missing debit/credit note adjustments
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Not reviewing GSTR-1A amendments
Each of these may invite notices or scrutiny under Sections 65, 66 or 70.
Conclusion
GSTR-9 and GSTR-9C filing for FY 2024-25 demands a high level of diligence, technical expertise, and documentation accuracy.
With increased data validations and cross-check mechanisms, businesses must adopt a proactive and structured compliance approach.
A Chartered Accountant’s involvement ensures:
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Accurate disclosures
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Robust reconciliation
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Audit-proof documentation
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Reduced compliance risk
At Pankaj Agrawal & Associates, we deliver PAN-India expertise in GSTR-9, GSTR-9C, GST audits, and litigation support, ensuring seamless and compliant annual return filing.
Contact for Professional Assistance
Pankaj Agrawal & Associates, Chartered Accountants (India)
📍 88, Jawahar Nagar, Near Rajendra Nagar, Indore, M.P.
📞 +91 79990 28234
📧 pankajagrawal0116@gmail.com
We provide GST Annual Return and Audit services across India.
