CGST Notification 13/2025, effective 22 September 2025, overhauled GSTR-9 for FY 2024-25 returns filed in India. The 6A1/6A2 split isolates cross-year ITC from current-year ITC. Table 7 now separately tracks Rule 37 and Rule 37A reversals. Table 9 breaks ITC utilisation into four tax-head columns. GSTR-9C adds e-commerce operator §9(5) disclosure rows and a standalone late-fee table. Provisional refund orders under Rule 91 must be issued within 7 mandatory days.
TL;DR for founders
Your CA or tax consultant filing the annual GSTR-9 for FY 2024-25 — due in late 2025 or early 2026 — will encounter new tables that did not exist in prior years. The most significant change for most businesses: if you received invoices from suppliers who filed their GSTR-1 late (in the next financial year's April–October window) and you claimed that ITC in the same window, that cross-year ITC must now be separately identified in a new sub-item 6A1. App-based platform sellers and e-commerce operators face new GSTR-9C reconciliation rows tied to the Section 9(5) CGST Act liability. Exporters and inverted-duty-rate claimants benefit from a stricter 7-day provisional refund timeline. Brief your finance team before the return prep cycle begins.
Background
The GSTR-9 annual return consolidates a full year of GST transactions — outward supplies, inward supplies, ITC availed and reversed, tax paid, and closing liabilities — into one reconciliation statement. For most businesses with turnover above ₹2 crore, the annual return includes GSTR-9C, the reconciliation statement certified by a chartered accountant or cost accountant.
GST's inherent cross-year ITC problem has persisted since the return's introduction. Under Section 16(4) of the Central Goods and Services Tax Act, 2017 ('CGST Act'), ITC on invoices of a given financial year may be availed up to the date of filing the September return of the next year (effectively October of the following year). Suppliers who file GSTR-1 late — sometimes as late as July or August of the year after the invoice date — create ITC that the recipient legitimately claims in the next year's GSTR-3B. That ITC shows up in GSTR-9 for the year it was availed, not the year the invoice was issued. Until FY 2023-24, the annual return form had no mechanism to separate this cross-year ITC from genuine current-year ITC, creating reconciliation opacity.
CGST Notification 13/2025 also introduced the procedural framework for the GST Appellate Tribunal through amendments to Rules 110-113 and insertion of new Rule 110A — covered in the companion article on GSTAT appeal procedure and Form APL-02A.
Table 6: The 6A1/6A2 Cross-Year ITC Split
Serial 6A in Part III of GSTR-9 captures total ITC availed through GSTR-3B during the financial year. For FY 2024-25 onwards, two new sub-items sit beneath 6A.
Sub-item 6A1: Cross-year ITC of the preceding financial year. This captures ITC pertaining to FY 2023-24 that was availed in FY 2024-25's GSTR-3B filings — specifically the April-to-October 2024 returns filed up to 30 November 2024 (the §16(4) window). The instruction explicitly excludes from 6A1 any ITC reclaimed after a reversal under Rule 37 (non-payment to supplier) or Rule 37A (GSTR-2B mismatch) — those reclaimed amounts go in Serial 6H, not 6A1. The rationale: 6A1 is a disclosure item for genuinely "old year, new year availed" ITC; reclaimed ITC is a separate reconciliation event.
Sub-item 6A2: Net current-year ITC. Calculated as (6A minus 6A1), this represents ITC that both pertains to FY 2024-25 invoices and was availed within the same year's GSTR-3B cycle. This is the figure that actually corresponds to the business's current-year procurement activity.
Why Serial J has been updated. The reconciliation serial J in Table 6 was previously computed as (I minus A), where A was the gross 6A figure. From FY 2024-25, the formula becomes (I minus A2), where A2 is the net 6A2. This is the substantive policy change: the reconciliation now correctly compares only current-year ITC against the supplies declared for the current year. Previously, auditors had to manually carve out cross-year ITC to reach this figure; now the form does it structurally.
Practical audit implication. Businesses that habitually avail a significant portion of ITC in April–October of the next year — common in industries with long payment cycles, or where vendors are small businesses with irregular GSTR-1 filing habits — will see 6A1 as a non-trivial number. If the ERP does not already tag invoices by the financial year they pertain to versus the financial year the ITC is availed, the FY 2024-25 annual return preparation will require a manual sort. Finance teams should begin this segregation exercise at the start of the next year rather than at return-filing time.
6M updated. Serial 6M, which captures ITC availed through forms other than GSTR-3B, now explicitly lists Form ITC-01, Form ITC-02, and Form ITC-02A — all three transfer or re-avail mechanisms — and excludes TRAN-1 and TRAN-II (transition-era forms, no longer active for new availed ITC). This is a clarificatory change rather than a substantive one.
Table 7: Separate Tracking of Rule 37 vs Rule 37A Reversals
Part III of GSTR-9 records ITC reversals and ineligible ITC in Serial 7. The FY 2024-25 form introduces two new sub-items under the existing Serial 7A.
Sub-item 7A1 — Rule 37 reversal. Rule 37 of the CGST Rules, 2017 requires a taxpayer to reverse ITC claimed on an invoice if payment to the supplier is not made within 180 days of the invoice date. The reversal obligation is self-assessed and must be reflected in GSTR-3B for the relevant period. Prior to this change, Rule 37 and Rule 37A reversals were both aggregated in the single Table 7A line, making it impossible for the department to distinguish the two without a notice.
Sub-item 7A2 — Rule 37A reversal. Rule 37A was introduced through the Finance Act 2022 and operates on GSTR-2B matching logic: if a supplier has not discharged the tax underlying an invoice and consequently has not filed GSTR-3B, the ITC reflected in the recipient's GSTR-2B from that supplier must be reversed. The reversal is system-prompted through GSTR-2B-linked auto-population rather than purely self-assessed. Because the department's system already holds the GSTR-2B data that triggers Rule 37A, separate disclosure in 7A2 enables automated cross-verification without manual scrutiny.
Auto-population expectation. The GSTN portal is expected to auto-populate 7A2 from GSTR-2B data for the annual return, since the matching dataset is system-generated. Finance teams should reconcile the auto-populated 7A2 against their own records before finalising the return — discrepancies may indicate periods where GSTR-2B was recomputed after the filing of GSTR-3B.
Table 8H1 and Serial I: IGST Import ITC Carryover
A targeted addition addresses the scenario where IGST credit on import of goods is carried into the next financial year — specifically where the goods crossed the customs frontier in late March but the Bills of Entry were assessed and the IGST paid after 1 April, resulting in the ICEGATE data flowing into the next year's GSTR-2B.
New Serial 8H1 — "IGST Credit availed on import of goods in next financial year" — captures this carryover separately from Serial 8H (IGST credit availed in the current year). The reconciliation Serial I, which computes the difference between declared import ITC (G) and credit actually availed (H plus H1 combined), is updated accordingly. Importers with year-end shipments should ensure the classification between H and H1 is correctly populated to avoid inflating the "ITC leakage" figure in Serial I.
Table 9: Expanded Tax-Paid Columns
Table 9 records the tax payable and paid for each tax head across the financial year. The most operationally consequential structural change in the FY 2024-25 form is the expansion of the ITC-paid column from a single aggregated figure to four separate columns: Central Tax, State/UT Tax, Integrated Tax, and Cess.
Why this matters. The CGST Act's ITC utilisation rules prescribe a specific order: IGST credit is used first (against IGST, then CGST, then SGST/UTGST); CGST credit is used against CGST and then IGST; SGST/UTGST credit is used against SGST/UTGST and then IGST. A single aggregated "paid through ITC" column made it impossible for the system to automatically verify compliance with these utilisation rules without a separate enquiry. The four-column structure makes the utilisation pattern visible at the return stage itself.
Practical compliance check. For each row in Table 9 (Integrated Tax payable, Central Tax payable, State/UT Tax payable, Cess payable, Interest, Late Fee, Penalty, and Other), the total payment is now the sum of cash paid plus all four ITC columns. The Difference column — residual liability after all credits and cash — should be zero or positive. A negative Difference indicates excess payment and is a refund-eligible amount. Finance teams reviewing the Table 9 draft should verify that the ITC column split aligns with the credit ledger statements downloaded from the GSTN portal for each period of FY 2024-25.
Part V Updates: Tables 10-14
Part V of GSTR-9 captures cross-year transactions — supplies and ITC that straddle the FY boundary and were reported in the next year's returns.
Table 10 captures outward supplies of FY 2024-25 that were declared through invoices, debit notes, or amendments in the April-to-October 2025 GSTR-1 filings (filed up to 30 November 2025). These are additional taxable supplies from FY 2024-25 reported in the next year.
Table 11 is the downward equivalent — credit notes issued against FY 2024-25 supplies but declared in the next year's April–October returns.
Table 12 captures ITC reversal of FY 2024-25 that was effected in the next year's returns (April–October 2025) and was not already reported in Table 7 of the FY 2024-25 GSTR-9 itself.
Table 13 records ITC on FY 2024-25 inward supplies availed in the next year's GSTR-3B returns for April–October, filed up to 30 November 2025. The FY 2024-25 instruction introduces a specific carve-out: ITC reversed under Rule 37 or Rule 37A in FY 2024-25 but subsequently reclaimed after supplier compliance in the next year should be reported in Table 6H of the FY 2025-26 GSTR-9 — not in Table 13 of the FY 2024-25 return. This prevents the same ITC from appearing both as a carry-forward in Table 13 and as a reclaim in the subsequent year's 6H.
Table 14 records the differential tax payable on the declarations in Tables 10 and 11, with columns for Payable, Paid, and the net Difference for all four tax heads plus Interest.
GSTR-9C Changes: D1/K-2 and Table 17
GSTR-9C, the reconciliation statement for taxpayers above the audit threshold, picks up two structural additions for FY 2024-25.
Serial D1 — Supplier disclosure of §9(5) supplies. Section 9(5) of the CGST Act, 2017 designates the e-commerce operator (ECO) — not the actual supplier — as the person liable to pay GST on certain categories of supplies facilitated through their platform: restaurant services, passenger transport (radio-taxi, bike taxi), accommodation services, housekeeping services, and online gaming. Where a supplier makes such supplies through an ECO and the ECO discharges the tax, the supplier's own turnover in GSTR-9C would otherwise appear understated when reconciled against the declared supplies in GSTR-1 and GSTR-3B. New Serial D1, inserted in Part II of GSTR-9C, requires the supplier to separately disclose these §9(5) supplies so they are correctly excluded from the taxable turnover reconciliation and no phantom discrepancy is flagged.
Serial K-2 — ECO disclosure of §9(5) liability. The mirroring disclosure on the ECO's own GSTR-9C (Serial K-2) captures the reverse side of the same transaction: the supplies on which the ECO was required to pay tax as the deemed supplier under §9(5). Together, D1 and K-2 enable a system-level cross-check between supplier and operator declarations for the same category of transactions.
Serial Q — "payable" replaces "paid". A correction to Serial Q changes the description from "paid" to "payable," aligning the reconciliation terminology with the liability-quantification logic of the rest of Part III of GSTR-9C.
Table 17 — Late fee payable and paid. A new standalone table separately captures late fee liability for the annual return itself — columns for Payable and Paid broken down by Integrated Tax, Central Tax, and State/UT Tax. Late fee disputes (including those arising from system-generated late-fee orders after the GSTAT becomes operational) will now be documented at the GSTR-9C stage with a standard quantification template, making them easier to trace if a demand is raised.
Rule 91 Provisional Refund: 7-Day Mandatory Timeline
Rule 91 of the CGST Rules governs provisional refund — the mechanism under which 90% of an admitted refund claim is released quickly without waiting for the full verification process.
Old regime. Before the amendment, the rule gave the proper officer discretion on timing. In practice, provisional refund orders under Form GST RFD-04 were frequently delayed for weeks or months — a significant working-capital burden for exporters on zero-rated supplies and manufacturers operating under an inverted duty rate structure.
New sub-rule (2). A new sub-rule inserted by CGST Notification 13/2025 mandates that the proper officer issue Form GST RFD-04 within 7 days of acknowledgment of the refund application under Rule 90. The 7-day clock is triggered by system-identified risk assessment — the officer's role in the first pass is to review the system's risk flag and either issue the provisional order or invoke one of the two provisos.
Two provisos. First, the officer may decline to issue a provisional order if there are written reasons justifying a skip to the final order under Rule 92 — for instance, where the refund is clearly inadmissible on the face of the application. Second, the RFD-04 order does not require revalidation. The revalidation step, which previously existed and added a further delay before the refund warrant could be issued by the Pay and Accounts Office, has been removed.
Practical benefit. For exporters and inverted-duty claimants, the 7-day mandatory provisional refund converts what was an indefinite administrative wait into a legally enforceable deadline. If the officer neither issues RFD-04 nor provides written reasons for declining within 7 days, the default becomes that provisional refund must proceed — taxpayers can escalate to the jurisdictional GST Commissionerate on day eight.
Founder checklist
- Brief your CA or finance head on the 6A1/6A2 split before the FY 2024-25 return preparation begins — check whether your ERP or accounting software tracks ITC by the financial year the invoice pertains to, not just the year it was availed.
- If your business sells through app-based platforms (food delivery, ride-hailing, accommodation, housekeeping, or online gaming), confirm with your ECO whether §9(5) applies and prepare the Serial D1 disclosure for GSTR-9C.
- If you are an e-commerce operator facilitating §9(5) supplies, prepare your Serial K-2 data extract separately from the routine annual return preparation pack.
- If your business exports goods or operates under an inverted duty rate, note that provisional refund must now be issued within 7 days of acknowledgment — track the Rule 90 acknowledgment date and escalate if no RFD-04 arrives within the window.
- Download your GSTR-2B credit ledger for each month of FY 2024-25 and cross-check the Rule 37A (7A2) auto-population in Table 7 against your internal reversal records before filing.
FAQ
Q: What is the difference between Table 6A, 6A1 and 6A2 in GSTR-9 for FY 2024-25?
A: From FY 2024-25, Table 6 in GSTR-9 introduces two sub-items under serial 6A (ITC availed through GSTR-3B). Sub-item 6A1 captures ITC of the preceding financial year that is availed in the current year's GSTR-3B (April–October) — this is cross-year ITC that is included in the gross 6A figure. Sub-item 6A2 (= 6A minus 6A1) represents the net ITC that genuinely pertains to the current financial year. The reconciliation serial J is updated to compare against 6A2 (not the gross 6A), ensuring auditors measure only current-year ITC against the declared figures.
Q: Why are Rule 37 and Rule 37A reversals now tracked separately in Table 7?
A: Rule 37 CGST Rules requires ITC reversal when a supplier is not paid within 180 days of invoice date. Rule 37A CGST Rules (inserted by Finance Act 2022, effective from FY 2021-22) requires ITC reversal when the supplier has not filed GSTR-3B and the ITC is reflected in GSTR-2B. Previously, both reversals were aggregated in Table 7A. From FY 2024-25, sub-items 7A1 (Rule 37) and 7A2 (Rule 37A) are separately reported, allowing the department to cross-verify Rule 37A reversals against the GSTR-2B matching data the system already holds.
Q: What does the expanded Table 9 in GSTR-9 FY 2024-25 change for compliance?
A: Table 9 (tax payable and paid) now has four separate columns for ITC utilisation: Central Tax, State/UT Tax, Integrated Tax, and Cess — replacing the single aggregated ITC column in prior years. For each row (Integrated Tax, Central Tax, State/UT Tax, Cess, Interest, Late Fee, Penalty, Other), the total paid = cash paid + sum of four ITC columns. The expanded breakout enables the department to cross-verify that ITC was applied in the correct utilisation order (CGST ITC used for CGST/IGST, IGST ITC for IGST/CGST/SGST) without a separate query.
Q: What is the new D1 row in GSTR-9C and who must fill it?
A: Serial D1, inserted in Part II of GSTR-9C for FY 2024-25 onwards, captures "Supplies on which tax is to be paid by e-commerce operators as per Section 9(5) of the CGST Act, 2017." It is filled by the SUPPLIER (not the operator). Where a supplier makes taxable supplies through an app-based aggregator (restaurant services, transport, accommodation, housekeeping, online gaming) and the GST on those supplies is discharged by the e-commerce operator under §9(5), the supplier must include those supplies in D1 so they are excluded from the taxable turnover reconciliation. The mirroring serial K-2 is filled by the E-COMMERCE OPERATOR.
Q: How does the GSTR-9 Part V Table 13 change affect ITC availed in next year?
A: Table 13 in Part V captures ITC on inward supplies of the current financial year that is availed in the next year's GSTR-3B for April–October, filed up to 30th November. This is the ITC that crosses the FY boundary lawfully under the Section 16(4) CGST Act deadline. From FY 2024-25, the instruction explicitly states: ITC reversed under Rule 37 or Rule 37A in the preceding year but reclaimed in the next year should be reported in Table 6H (not Table 13), preventing double-counting.
Q: What changed in provisional refund Rule 91 under CGST Notification 13/2025?
A: Rule 91(2) CGST Rules now mandates that the proper officer issue Form GST RFD-04 (provisional refund order for 90% of the claimed refund) within 7 days of acknowledgment under Rule 90, based on system-driven risk identification. Two important changes: first, the 7-day timeline is now mandatory (not discretionary); second, the provisional order does not require revalidation — the earlier revalidation step that caused delays is removed. A proviso allows the officer to decline provisional sanction (in writing) and proceed directly to the final order under Rule 92 if the risk profile warrants it.
Sources
- CBIC Tax Information Portal: taxinformation.cbic.gov.in
- CGST Act, 2017 — Sections 9(5), 16(4): indiacode.nic.in
- eGazette (Notification text): egazette.gov.in
Go deeper with Veritect Legal AI
The changes to GSTR-9 for FY 2024-25 described in this article cover the structural framework — the full compliance picture includes the instruction-level detail for each table, the auto-population logic governing which GSTR-2B line items feed 7A2, the specific exclusion instructions for Table 13 versus Table 6H, and how the expanded Table 9 ITC columns interact with the credit-ledger utilisation statements for Section 49 of the CGST Act, 2017. Veritect Legal AI holds the complete text of CGST Notification 13/2025 alongside the prior GSTR-9 amendment history, enabling queries such as "what changed between the FY 2023-24 GSTR-9 form and FY 2024-25" or "how does 6A1 interact with the ITC reversal chain under Rule 37A for a taxpayer who was both a supplier and a recipient in the same period." Subscribers in the e-commerce and export sectors also have access to the §9(5) operator liability analysis and the Rule 91 provisional-refund escalation playbook. Access through veritect.ai.
Related on Veritect: GST annual return: FORM GSTR-9, GSTR-9C and the §44 regime