As businesses prepare their annual GST compliance for FY 2024-25, this year brings some of the most important updates introduced in GSTR-9 and GSTR-9C. The GSTN has released a fresh FAQ and updated system logic that directly impacts ITC reporting, import ITC, GSTR-1A adjustments, auto-population rules, and even late fee calculations. These changes are not cosmetic; they fundamentally alter how taxpayers must reconcile their annual data with GSTR-1, GSTR-3B, and GSTR-2B.
To help taxpayers stay compliant and avoid reporting errors, this comprehensive guide breaks down every new change in GSTR-9 and GSTR-9C for FY 2024-25—what has changed, why it matters, and how to report your data accurately. Whether you are preparing the annual return yourself or reviewing it professionally, this article serves as a complete reference for the updated requirements.
GSTR-9 Enabled Only After Complete Filing of GSTR-1 and GSTR-3B
For FY 2024-25, GSTR-9 and GSTR-9C will be enabled only if:
- All GSTR-1 (or GSTR-1A/IFF) of FY 2024-25 are filed
- All GSTR-3B returns of FY 2024-25 are filed
If any return is pending, the system will not enable the annual return.
This ensures that auto-population of Tables 4, 5, 6, 8 and 9 happens only after the complete dataset from regular returns is available.
Inclusion of GSTR-1A Supplies in Auto-Population of Tables 4 & 5
Starting FY 2024-25 as GSTR-1A was introduced, the Supplies added or amended through GSTR-1A will also be included
This affects Table 4 (Outward taxable supplies) and Table 5 (Exempt, nil-rated, non-GST supplies).
This aligns annual return data more accurately with the actual outward liability declared.
Major Overhaul in Input Tax Credit Reporting (Tables 6A, 6A1, 6A2, 6B–6H)
1. Introduction of Table 6A1
A new row, Table 6A1, has been introduced.
The form now has the disclosure of ITC of preceding FY 2023-24 claimed in GSTR-3B of FY 2024-25 which means the populated number in table 6A2 will get completely matched with ITC as per books of account viz a viz ITC as per GSTR-3B for the year 2024-25.
Further, the ITC which is reclaimed in the year 2024-25 which was earlier reversed owing to Rule 37 (Payment not made within 180 days) or Rule 37A (ITC not appearing in GSTR-2B owing to taxes not paid by vendor) need not be disclosed in the said column as the same will be shown separately in column 6H.
This change ensures that ITC of previous years does not get included in the current year’s ITC availability as the case was there upto annual returns for the period 2023-24.
2. Impact of 6A1 on 6A2
- Table 6A2 = 6A – 6A1
- 6A2 now accurately reflects current year ITC only.
This eliminates mismatches earlier seen in Table 6J.
3. Correct Reporting of Reversed & Reclaimed ITC (Rule 37/37A)
If ITC is:
- Claimed
- Reversed
- Reclaimed
The reporting depends on whether reclaim happens in the same FY or the next FY, and whether the reason is Rule 37/37A or other reasons (like Circular 170/02/2022-GST).
Key rules for FY 2024-25:
|
Scenario |
Where to Report |
|
ITC claimed → reversed → reclaimed all in 2024-25 |
6B (claim), 7 (reversal), 6H (reclaim) |
|
Reclaim in next FY due to Rule 37/37A |
Report reclaim in 6H of next FY only |
|
Reclaim in next FY for reasons other than 37/37A |
Report reclaim in 13 of current FY and 6A1 next FY |
This update is one of the most important compliance changes of FY 2024-25.
Table 6M: Label Updated but No Change in Reporting
The label has been aligned with the government-notified form.
Report ITC from:
- ITC-01
- ITC-02
- ITC-02A
No procedural change otherwise.
Complete Overhaul of Table 8 Series (8A, 8B, 8C, 8D, 8H1)
- Table 8A: Enhanced Auto-Population Logic
Table 8A now includes:
- All inward supplies of FY 2024-25 appearing in GSTR-2B of FY 2024-25
- Invoices of FY 2024-25 appearing in GSTR-2B from April 2025 to October 2025
- Excludes invoices of FY 2023-24 appearing in 2B between April 2024–October 2024
8A Excel vs 8A Online May Differ
Because:
- RCM outward supplies appear only in Excel
- Amendments from normal charge → RCM appear only in Excel
- PoS amendments making ITC ineligible show only in Excel
- FY change amendments show differences
- Online 8A contains only eligible 2B entries
Online 8A is considered correct for GSTR-9 filing.
2. Table 8B: ITC from 6B Only (6H Delinked)
Earlier, reclaimed ITC (6H) influenced 8B in the annual return for the period upto March 2024 which was the main reason for difference and notices in table 8D. GST department officials were blindly issuing notices on the basis of differences appearing in table 8D without understanding the working modality of the same.
With effect from FY 2024-25:
- Table 8B auto-populates only from 6B
- No link with 6H (reclaimed ITC)
This prevents differences in 8D that were common earlier and hopefully settle the unwanted notices from the department.
3. Table 8C: Only Missed ITC Claimed Next Year
Table 8C must NOT include:
- ITC claimed and reversed in same FY and reclaimed next FY
- ITC reclaimed under Rule 37 or 37A next FY
Table 8C will only contain:
- Missed ITC of FY 2024-25 claimed first time in FY 2025-26 (up to the specified period)
- ITC where the supplier uploaded the invoice in GSTR-1 during April–October 2025 and the recipient claimed it next year
These amounts also appear in Table 13.
4. New Table 8H1: ITC on Imports Claimed Next FY
A new row 8H1 has been inserted.
Report here:
- IGST paid on imports in FY 2024-25
- ITC claimed in FY 2025-26
This ensures that:
- 8G reports IGST paid
- 8H1 reports ITC claimed
- 8I shows NIL difference
This is one of the most important structural changes.
Table 12 & 13: Label Changes Only to provide clear meaning
- Table 12 → ITC of FY 2024-25 reversed in next FY
- Table 13 → ITC of FY 2024-25 availed in next FY
No change in data treatment.
Table 17 (HSN Summary): New Download Utility
A new Excel utility is provided:
- “Download Table 12 of GSTR-1/1A HSN Details”
- Includes an additional sheet in the format of Table 17
Taxpayers can directly use this to report accurate HSN data in GSTR-9.
Removal of 65% Concessional Rate Column
The 65% concessional rate checkbox is removed from:
- Table 17
- Table 18
- Both online and offline tools
Since this concessional mechanism is no longer applicable, the field has been fully discontinued.
Negative Liability vs Auto-Population of Table 9 Tax Payable
For FY 2024-25:
- If net liability in GSTR-3B Table 6.1 is positive, it auto-populates in Table 9
- If negative, Table 9 shows blank
- The field remains editable
This allows taxpayers to correctly adjust liability figures.
New Late Fee Mechanism for GSTR-9C (Important)
As per updated system behaviour:
- Late fee under Section 47(2) now applies to the complete annual return, including both GSTR-9 and GSTR-9C (if applicable).
- A new table Table 17 – “Late Fee Payable and Paid” has been added to GSTR-9C.
How Late Fee Is Calculated:
- GSTR-9 late fee:
From due date → actual filing date
- GSTR-9C late fee:
From later of:
-
- Filing date of GSTR-9 OR
- Due date of annual return
→ till filing date of GSTR-9C
System auto-calculates based on actual dates.
This is one of the most significant changes introduced for FY 2024-25.
IMS (Input Tax Credit Matching System) Clarification
Actions on IMS dashboard do NOT directly impact GSTR-9.
- Accepted or deemed-accepted documents already reflect in GSTR-2B
- Hence they indirectly flow into Table 8A
Auto-Population Based on Supplier Amendments
Supplier amendments in GSTR-1/1A/IFF will affect 8A as long as:
- The amended invoice pertains to FY 2024-25
- If amendment shifts the invoice to another FY, the entry moves accordingly
- Online 8A reflects the latest correct GSTR-2B-based values
Frequently Asked Questions (FAQs)
1. Is GSTR-9 mandatory for FY 2024-25?
Yes, annual return filing continues to be mandatory for taxpayer with turnover above Rs.2 crores.
2. Is GSTR-9C required for all taxpayers?
No. It is applicable only if turnover exceeds the notified threshold currently Rs. 5 crore.
3. Do ITC reclaims under Rule 37/37A go to Table 8C?
No. They are not to be reported in 8C. Their reporting depends on whether the reclaim happens in the same year or the next year.
4. How do I report import IGST ITC claimed next year?
Use the newly added Table 8H1.
5. Are there changes in HSN reporting?
Yes. A new download utility is provided for Table 17 reporting.
Stay Compliance-Ready for FY 2024-25
The FY 2024-25 annual return brings several structural and reporting changes, particularly in ITC classification, import ITC reporting, 8-series tables, GSTR-1A integration, and late fee computation. Accurate reporting requires careful reconciliation of GSTR-1, GSTR-2B, GSTR-3B, and books of accounts.
If you need expert assistance in preparing or reviewing GSTR-9 or GSTR-9C:
PGACA can help.
PGACA specialises in:
- GST annual return preparation
- GSTR-9C reconciliation and certification support
- ITC matching and rectification
- End-to-end GST compliance for businesses and professionals
For professional, compliant and accurate GST assistance, PGACA (PGA&Co.) ensures your annual filings are completed well within timelines and align perfectly with GSTN requirements.
A mismatch is arising in Table 12C of GSTR-9C because the ITC received during FY 2024–25 but availed in FY 2025–26 up to the specified date is not reflected in Table 6A of GSTR-9, whereas it appears in Tables 8A and 8B. Further, Table 7J shows only the current year’s ITC, and the introduction of Table 6A1 has also affected the figures. We request guidance on how to correctly reconcile Table 12C in view of these reporting differences.