GSTR-9 & 9C for FY 2024-25: Key Changes

The CBIC, through Notification No. 13/2025 – Central Tax dated 17th September 2025, has made significant amendments to the Annual Return Form GSTR-9 & 9C. These changes, applicable from FY 2024-25 onwards, aim to improve accuracy in ITC reporting, reconciliation with GSTR-3B & 2B, and prior-period adjustments.

In this Handout, we explain the major changes in GSTR-9 & 9C for FY 2024-25 in a simple and practical way.

A. GSTR-9

1. New Sub-Tables for ITC Reporting (6A1 & 6A2)

• 6A1 – ITC of the preceding financial year availed in the current financial year (through GSTR-3B of April to October, filed till 30th November).
• 6A2 – Net ITC of the current financial year (after excluding 6A1).

2. Expansion of Table 6M

• Table 6M will now capture ITC availed through:
  • ITC-01 (credit on new registration/ voluntary registration),
  • ITC-02 / ITC-02A (credit transfer on merger/demerger, business transfer).

3. Linkage of ITC Reversal & Reclaim (Tables 6H & 7)

• ITC availed, reversed, and later reclaimed will now be disclosed in a linked manner:
  • ITC availed first time → Table 6B.
  • ITC reversed → Table 7.
  • ITC reclaimed → Table 6H.
• Special provisions:
  • If reversal was due to Rule 37 / 37A (non-payment to supplier) and reclaimed later → Report in 6H.
  • If reversal was due to other reasons and reclaimed → Report in 6A1.

3(a).Rule-Wise Reporting of ITC Reversals

Earlier, GSTR-9 only had a consolidated reporting of ITC reversals.
Now, from FY 2024-25, taxpayers must separately report reversals as per specific CGST Rules:

• Rule 37 – Non-payment to supplier within 180 days.
• Rule 37A – ITC reversal for supplier not paying tax (linked with GSTR-3B mismatch).
• Rule 38 – Reversal for banking companies (50% ITC option).
• Rule 39 – ISD distribution of credit.
• Rule 42 – Common ITC apportionment for exempt & taxable supplies (inputs/input services).
• Rule 43 – Capital goods ITC reversal.
• Section 17(5) – Blocked credits (e.g., motor vehicles, personal consumption).
• Transition Credit reversals – Claimed through TRAN-1/2 but later reversed.

4. New Disclosures for Import ITC

• Table No 8H1: IGST credit availed on imports in next financial year.
• 8H1: Out of 8G, the portion of ITC on imports availed in the next year must be disclosed separately.

5. Revised Tables 10–13 for Prior Period Adjustments

From FY 2024-25 onwards:

• Table 10: Upward amendments (invoices, debit notes) relating to current FY but reported up to October of next FY.
• Table 11: Downward amendments (credit notes, amendments) reported up to October of next FY.
• Table 12: Reversal of ITC relating to current FY but reported in next FY.
• Table 13: ITC relating to current FY availed in next FY (up to October).

6. Auto-Population of ITC in Table 8

For FY 2024-25 onwards, ITC declared in Table 6B will be auto-populated in Table 8B.

7. Instruction Updates

• Cut-off date: Transactions of a financial year can be corrected/adjusted only up to 30th November of next FY (aligned with Sec. 16(4) ITC rule).
• Language in instructions updated for FY 2024-25.

B. GSTR-9C

1. New Disclosure for E-Commerce Transactions (Section 9(5))

• A new row 7D1 has been added in Part II – Reconciliation of Turnover.
  • Supplies on which tax is to be paid by e-commerce operators u/s 9(5) must now be reported by the supplier.
• In Part III – Reconciliation of Tax Paid, a new row K-2 has been inserted.
  • E-commerce operators themselves must disclose such supplies on which they are liable to pay tax.

2. Reconciliation of Turnover – Revised Formula

• Earlier formula was E = (A-B-C-D).
• Now it is E = (A-B-C-D-D1) to account for new disclosure of e-commerce operator supplies.

3. Additional Liability Reporting Updated

• In Table 11 (Additional amount payable but not paid):
  • Earlier only “cash” was considered.
  • Now it covers cash or ITC as mode of settlement.
• Separate line item introduced for:
  • “Supplies on which e-commerce operator is required to pay tax u/s 9(5).”

4. Part V – Additional Liability on Non-Reconciliation

• Earlier: “Cash”
• Now: “Cash or ITC”
• Ensures all unsettled liabilities are captured whether payable through cash ledger or electronic credit ledger.

5. Late Fee Disclosure Added

• A new row added in Part V – Table 17 for Late Fee payable & paid under Section 47(2).
• Must be shown separately for IGST, CGST, SGST/UTGST.

6. Instruction Updates

• Year references updated to cover FY 2024-25.
• Specific instructions for e-commerce supplies:
  • Supplier must declare such supplies in 7D1.
  • Operator must declare in K-2.

Key Takeaways

1. Taxpayers must maintain rule-wise ITC registers (especially for Rule 37/37A reversals).
2. ERP/accounting systems should be updated to separately track:
   • ITC of current year,
   • ITC of previous year claimed this year,
   • ITC reversed & reclaimed.
3. Import-related ITC disclosures will require ICEGATE data reconciliation.
4. Prior-period amendments must be closely tracked and reported in the right table.
5. E-commerce operators now have direct liability reporting in GSTR-9C.
6. Suppliers selling via e-commerce platforms must also report such supplies distinctly.
7. Businesses must ensure dual reporting matches between supplier & operator.
8. Additional liabilities can now be tracked as cash or ITC, not just cash.
9. Late fee reporting made mandatory for FY 2024-25.