🔹 Introduction

Every registered taxpayer under GST (except a few categories) must file an annual return to consolidate their yearly transactions. In 2025, the key annual return forms are GSTR-9 and GSTR-9C. Filing these correctly helps avoid notices, penalties, and ensures compliance.

This guide explains everything about GSTR-9 & GSTR-9C with the latest updates.

(References: Sec. 44 of CGST Act, Rule 80, CBIC Notifications up to 2025)

🔹 Who Needs to File?

• GSTR-9: All regular taxpayers (turnover > ₹2 crore).

• Optional GSTR-9: Turnover up to ₹2 crore (filing optional as per current relaxation).

• Not required: Composition taxpayers (file GSTR-9A earlier, now withdrawn), casual taxable persons, non-resident taxable persons, ISD, TDS/TCS deductors.

• GSTR-9C (Reconciliation Statement): Required for taxpayers with aggregate turnover > ₹5 crore (self-certified, no CA/CMA audit mandatory since FY 2020-21).

⚠️ Update FY 2024-25 onwards: Section 74A (new unified penalty provision) applies to annual return mismatches, replacing Sec. 73 & 74.

🔹 Due Dates

• GSTR-9 & 9C: 31st December of following financial year.
  (Example: FY 2024-25 → Due by 31st Dec 2025).

Late filing → Late fee + interest.

🔹 Structure of GSTR-9

Part I: Basic details (GSTIN, legal & trade name).
Part II: Details of outward & inward supplies (taxable, exempt, nil-rated).
Part III: ITC declared in returns & reversals.
Part IV: Tax paid (cash/credit ledger).
Part V: Amendments for previous FY.
Part VI: Other information (demands, refunds, HSN summary).

🔹 Structure of GSTR-9C

• Part A (Reconciliation Statement):

  • Turnover as per audited financials vs GSTR-9.

  • Tax paid as per books vs GSTR-9.

  • ITC claimed as per books vs GSTR-9.

• Part B (Certification): Self-certified by taxpayer (earlier by CA/CMA).

🔹 Step-by-Step Filing Process

📌 Step 1: Login to GST Portal
Navigate to Services → Returns → Annual Return.

📌 Step 2: Select Form
Choose GSTR-9 (and GSTR-9C if applicable).

📌 Step 3: Auto-populated Data
System pulls data from GSTR-1, GSTR-3B, and GSTR-2B.

📌 Step 4: Verify & Reconcile

• Match turnover with books.

• Match ITC with 2B & financial statements.

• Verify taxes paid.

📌 Step 5: Enter Amendments (if any)
Report corrections related to previous FY.

📌 Step 6: Submit & File
Use DSC/EVC. ARN generated.

📌 Step 7: For GSTR-9C
Fill reconciliation statement online → Self-certify.

🔹 Common Mistakes to Avoid

1. Declaring wrong ITC figures not matching 2B.

2. Not reporting amendments for earlier FY.

3. Ignoring exempt & nil-rated supplies.

4. Filing late → Heavy late fees.

✅ Tip: Reconcile books vs returns vs 2B before filing.

🔹 Penalties & Late Fees

• GSTR-9 late fee: ₹200 per day (₹100 CGST + ₹100 SGST), max 0.25% of turnover.

• GSTR-9C: Penalty under Sec. 125 (general penalty up to ₹25,000).

• Wrong reporting → Liabilities under Sec. 74A (effective FY 2024-25).

🔹 FAQs

Q1. Is GSTR-9 mandatory for turnover < ₹2 crore?
➡️ No, it is optional.

Q2. Is CA/CMA audit mandatory for GSTR-9C?
➡️ No, only self-certification required.

Q3. Can GSTR-9 be revised?
➡️ No, once filed cannot be revised.

Q4. Is ITC reversal required in GSTR-9?
➡️ Yes, if wrongly claimed earlier.

Q5. Do composition taxpayers file annual return?
➡️ No, GSTR-9A withdrawn.

🔹 Best Practices

• ✅ Start reconciliation early (don’t wait till Dec).

• ✅ Use 2B & books to cross-check ITC.

• ✅ Maintain HSN-wise data for reporting.

• ✅ Keep track of amendments from previous FY.

🔹 Conclusion

Annual returns (GSTR-9 & 9C) are the final compliance step each year. A careful reconciliation ensures no notices, penalties, or ITC loss. With Sec. 74A in effect, accuracy is more important than ever.

📌 Need expert help with reconciliation or GSTR-9C filing?
Contact Tech-Tax Solutions – Quality, Trust & Expertise in Ghaziabad, Noida & Delhi.