🧾 GSTR-9 & 9C FY 2024-25 – Complete Expert Guide with FAQs
Updated on 15 October 2025 | Author – GST Excel Mastery Team
1️⃣ Legal Background & Applicability
Section 44 of the CGST Act requires every registered person (except composition taxpayers, TDS/TCS deductors, and casual/non-resident taxpayers) to file an annual return in Form GSTR-9. Where turnover exceeds ₹5 crore, Form GSTR-9C (reconciliation statement certified by CA/CMA) is also mandatory as per Section 35(5) read with Rule 80.
| Taxpayer Type | Return Required |
|---|
| Turnover ≤ ₹2 crore | Optional GSTR-9 (FY 24-25 notification expected) |
| ₹2 – 5 crore | GSTR-9 mandatory | 9C not required |
| > ₹5 crore | Both GSTR-9 and 9C compulsory |
2️⃣ Due Date & Filing Timeline
Statutory due date: 31 December 2025 for FY 2024-25. Late fee as per Section 47(2) applies @ ₹200 per day (₹100 CGST + ₹100 SGST) subject to 0.5% of turnover in State.
3️⃣ Major Schema & Portal Changes for FY 2024-25
- Introduction of two new ITC tables – 6A1 and 6A2
- Revamped Table 8A-8C auto-population based on GSTR-2B
- New import row 8H1 for deferred ITC on imports
- Auto-calculated late fee in GSTR-9C Part V
- Downloadable Excel for invoice-wise Table 8A data and HSN summary support
4️⃣ Understanding Table 6A1 & 6A2 – Bifurcation of ITC Claimed
To avoid duplication and improve transparency, GSTR-9 now requires split reporting of input tax credit:
- Table 6A1 – ITC pertaining to previous FY (2023-24) claimed in current FY 2024-25 till 30 Nov 2025.
- Table 6A2 – Net ITC for FY 2024-25 only (= 6A – 6A1).
Example: IGST ₹50,000 of Mar 2024 invoice claimed in Apr 2024 → report under 6A1. ITC of May 2024 invoice claimed in May 2024 → 6A2.
5️⃣ Table 8A-8C – Auto ITC Matching with GSTR-2B
8A: ITC as per GSTR-2B of FY 2024-25 (including Apr-Oct 2025 returns).
8B: ITC availed as per books (6B). Reclaim 6H no longer auto-added.
8C: ITC of FY 24-25 claimed next FY till 30 Nov 2025.
Example: A March 2025 invoice reported by supplier in Apr 2025 GSTR-1 → appears in 2B of Apr 2025 and auto-populates Table 8A.
6️⃣ Rule 37 & 37A – Reversal and Reclaim Logic
- Rule 37: Reverse ITC if supplier not paid within 180 days; reclaim when paid later.
- Rule 37A: Reversal if supplier missed reporting invoice in 2B by 30 Nov of next FY; reclaim after it appears.
If you claimed ₹1 lakh in Jun 2024 but payment made in Dec 2024 → reverse in Oct return (Table 7A), reclaim after payment (Table 6H).
7️⃣ IMS (Invoice Management System) Impact
IMS actions (Accept, Pending, Reject) don’t directly alter GSTR-9 values but they determine which invoices flow into GSTR-2B → and therefore Table 8A. Accepted and Deemed Accepted invoices count toward available ITC.
8️⃣ Filing Flow and Checklist
- File all GSTR-1 and 3B of FY 2024-25.
- Reconcile books vs 2B (month-wise).
- Prepare ITC bifurcation (6A1 & 6A2) and reversal summary (7A/7H).
- Download Table 8A Excel for cross-check.
- Compute turnover & tax payable differences in 9C.
- Upload JSON & submit after CA certification.
9️⃣ Penalties & Legal Consequences
- Late fee u/s 47(2): ₹200 per day (max 0.5% of turnover in State/UT)
- Misreporting or incorrect reconciliation may attract audit u/s 65 or scrutiny u/s 61
- Voluntary correction can be made through DRC-03 payment before submission
🔟 Practical FAQs – Answered by Experts
Q1. Is GSTR-9 optional for turnover below ₹2 crore?
Yes. As per past notifications, it is optional for ≤ ₹2 crore; official notification for FY 2024-25 is expected soon.
Q2. Should I report FY 23-24 ITC claimed in Apr 2024 in Table 6A or 6A1?
Such ITC belongs to previous year → report in Table 6A1 only.
Q3. If ITC was claimed and reversed in same FY but reclaimed next FY?
Report reversal in 7A/7H of FY 24-25 and reclaim in Table 6H of FY 25-26.
Q4. How to report import IGST ITC availed next year?
Declare IGST amount in 8G (FY 24-25), and the credit availed in next FY in new Table 8H1 + Table 13.
Q5. Can IMS “Pending” invoices be claimed later?
Yes. If accepted in later months, they appear in subsequent GSTR-2B and will be reported in 8C & 13 of the respective year.
🧮 Quick Reference Example
| Event | Month | Rule | Report FY 24-25 | Report FY 25-26 |
|---|
| Claim ITC ₹1,00,000 | Apr 2024 | – | Table 6B | – |
| Reverse ₹1,00,000 | Oct 2024 | Rule 37 | Table 7A | – |
| Reclaim ₹1,00,000 | Apr 2025 | Rule 37 | – | Table 6H |
📅 Key Takeaways
- File all returns before starting GSTR-9
- Use 6A1/6A2 split for accurate ITC reporting
- Verify Table 8A auto values with portal Excel
- Rule 37A reclaim only when invoice appears in 2B
- Maintain invoice-wise ITC register to avoid scrutiny
📚 GSTR-9 / 9C FY 2024-25 — Frequently Asked Questions
Still have queries after reading the guide? Explore our detailed GSTR-9 & 9C FY 2024-25 FAQ section —
covering official GSTN clarifications on Table 6A1/6A2, Table 8A–8C, Rule 37A, IMS impact, imports (8H1), late fee and more, explained with examples.