GSTR-9 FY 2024-25, 31 December 2026 last-mile checklist.

• GSTR-9 (Annual Return): mandatory for every registered taxpayer with aggregate turnover above INR 2 crore in FY 2024-25. Below INR 2 crore - filing is optional.
• GSTR-9C (Reconciliation Statement): mandatory for turnover above INR 5 crore. Self-certified (CA certification requirement removed from FY 2020-21 onwards).
• Exempt from GSTR-9: Casual Taxable Person, Non-Resident Taxable Person, Input Service Distributor, Composition dealer (GSTR-9A instead), TDS collector (GSTR-7), TCS collector (GSTR-8).
• Due date: 31 December 2026 for FY 2024-25. CBIC typically extends via notification; verify current status before 31 December.
• Late fee: INR 200 per day (INR 100 CGST + INR 100 SGST), capped at 0.25% of turnover. Section 47 CGST Act.

Reconciliation 1: GSTR-1 vs GSTR-3B turnover

• Compare outward supplies declared in GSTR-1 (invoice-level) with turnover reported in GSTR-3B (summary).
• Mismatch common causes: invoice entered in 3B but not pushed to 1; invoice in 1 but 3B understated; credit notes / debit notes timing differences.
• Resolution: amend GSTR-1 (for prior-period invoice correction) OR amend 3B (for current-period reconciliation) OR disclose in GSTR-9 Table 4/5 with narrative.

Reconciliation 2: GSTR-3B ITC vs GSTR-2B available ITC

• Rule 36(4) + Section 16: ITC claim must match vendor's GSTR-1 (reflected in 2B).
• If 3B ITC > 2B: shortfall must be reversed with Section 50 interest.
• If 3B ITC < 2B: forgone ITC - cannot be claimed later beyond Section 16(4) time limit.
• Resolution: reverse excess ITC via Form DRC-03 with interest; chase vendors for GSTR-1 filing to recover shortfall.

Reconciliation 3: Books of accounts vs GST returns

• Reconcile turnover in audited books with sum of GSTR-1 turnover.
• Common timing adjustments: credit notes issued in subsequent FY, discounts not shown in GST, year-end sales returns, exports in GSTR-1 vs books.
• Document reasons for differences in GSTR-9C Part II.

Reconciliation 4: Section 17(5) blocked ITC + Section 16(4) time-barred

• Section 17(5): ITC blocked on motor vehicles (seating < 13), construction material for own-use building, food/beverage, outdoor catering, personal insurance, membership of club. Must reverse via Table 7 of GSTR-9 with Section 50 interest.
• Section 16(4): ITC time limit - earlier of (a) due date of September's GSTR-3B of next FY (so FY 2024-25 ITC max claim window: October 2025 3B due date), OR (b) date of filing annual return for FY 2024-25.
• ITC missed within these windows is permanently time-barred - cannot be revived.

• Table 4: supplies on which tax is payable - outward supplies by nature (B2B, B2C, exports, SEZ, deemed exports, nil-rated, exempt, non-GST).
• Table 5: supplies on which tax is NOT payable - nil-rated, exempt, non-GST supplies.
• Table 6: ITC availed during FY - breakup by inputs, capital goods, input services.
• Table 7: ITC reversed / ineligible - Section 17(5) blocks, Rule 42/43 proportional, time-barred.
• Table 8: other ITC-related information - ITC as per 2B vs 3B claimed, shortfall / forgone.
• Table 9: payment of tax - CGST / SGST / IGST / cess payment schedule.
• Tables 10-14: amendments, demand, refund.
• Table 15: HSN-wise summary of outward supplies - HSN code + description + UQC + quantity + value + taxable value + tax amount.
• Table 16: HSN-wise summary of inward supplies (inputs + capital goods).

• Part I: identification details.
• Part II: reconciliation of turnover - audited books vs GSTR-9. Line-by-line adjustments.
• Part III: reconciliation of taxable supplies.
• Part IV: reconciliation of ITC - books ITC ledger vs GSTR-9 Table 6.
• Part V: reasons for unreconciled items.
• Self-certified by taxpayer (CA certification not required post FY 2020-21).
• Attach: audited balance sheet + audit report + any specific documents supporting reconciliation adjustments.

Last updated: 2026-10-22.