In India, §44 of the Central Goods and Services Tax Act, 2017 (CGST Act) read with Rule 80 of the CGST Rules, 2017 requires the annual return in FORM GSTR-9 by 31 December following the financial year. Registered persons up to ₹2 crore aggregate turnover are exempt; above ₹5 crore, the self-certified reconciliation statement in FORM GSTR-9C is also due.
TL;DR for founders
The annual return is not another monthly return. It is a consolidation: everything you already filed in twelve GSTR-1s and twelve (or four) GSTR-3Bs, restated in one place and then compared against your audited books. Nothing new can be claimed through it — you can pay more tax through it, but you cannot claim credit through it. Two turnover lines decide your obligation: ₹2 crore, below which you file nothing, and ₹5 crore, above which you also self-certify a reconciliation statement. Miss either and the clock runs at up to ₹200 a day until both are in.
Who files, and which form
Section 44 exempts five classes from the annual return: Input Service Distributors, tax deductors under §51, tax collectors under §52, casual taxable persons and non-resident taxable persons. Everyone else files — including QRMP taxpayers who file GSTR-3B quarterly, because the annual return is turnover-based, not frequency-based. Filing is per GSTIN, not per PAN, so a business registered in six States files six annual returns.
Rule 80 prescribes four forms:
| Form | Who files | Current status |
|---|---|---|
| GSTR-9 | Regular taxpayers filing GSTR-1 and GSTR-3B | Operative; due 31 December of the next financial year |
| GSTR-9A | Composition taxpayers under §10 | Not required from FY 2019-20 onwards — displaced by annual FORM GSTR-4 |
| GSTR-9B | E-commerce operators collecting TCS under §52 | Statutory form under §52(5) |
| GSTR-9C | Registered persons with aggregate turnover above ₹5 crore | Self-certified reconciliation statement under Rule 80(3) |
Two sectoral carve-outs sit outside this grid. Notification 30/2019-Central Tax (CGST_30_2019) exempts OIDAR service providers registered under §24 from both the annual return and the reconciliation statement. Notification 09/2020-Central Tax (CGST_09_2020) notifies a special procedure for foreign airline companies, exempting them from GSTR-9C subject to a statement of receipts and payments authenticated by a practising Chartered Accountant.
The two thresholds
₹2 crore — exemption from GSTR-9. The relief began as a §148 special procedure. Notification 47/2019-Central Tax (CGST_47_2019), explained by Circular 124/43/2019-GST (CIR_124_2019), deemed the annual return furnished on the due date for taxpayers up to ₹2 crore who had not filed it for FY 2017-18 and FY 2018-19 — which meant no late fee accrued. From FY 2020-21 the mechanism switched to a straight exemption under the first proviso to §44(1), renewed year by year: Notification 31/2021-Central Tax (CGST_31_2021) for FY 2020-21, Notification 10/2022-Central Tax (CGST_10_2022) for FY 2021-22, Notification 32/2023-Central Tax (CGST_32_2023) for FY 2022-23, Notification 14/2024-Central Tax (CGST_14_2024) for FY 2023-24 and Notification 15/2025-Central Tax (CGST_15_2025) for the current year.
₹5 crore — GSTR-9C. The reconciliation statement entered the Rules through Notification 49/2018-Central Tax (CGST_49_2018) as a CA- or CMA-certified audit annexure under the former §35(5) read with §44(2), applying above ₹2 crore. Notification 79/2020-Central Tax (CGST_79_2020) raised the audit threshold to ₹5 crore for FY 2018-19 and FY 2019-20. Notification 30/2021-Central Tax (CGST_30_2021) then substituted Rule 80 in full from 15 August 2021: the ₹5 crore threshold became permanent, Part B of FORM GSTR-9C — the auditor's certification — was omitted entirely, and the verification clause became a taxpayer self-affirmation. From FY 2020-21 the accountability for a reconciliation difference is the registered person's own.
Due dates have moved only by exception — Notification 40/2021-Central Tax (CGST_40_2021) extended FY 2020-21 filing to 28 February 2022. Notification 14/2022-Central Tax (CGST_14_2022) notified the FY 2021-22 forms, and Notifications 56/2019 (CGST_56_2019) and 79/2020 (CGST_79_2020) carried the optional-field relaxations for the early years.
Table by table
FORM GSTR-9 runs to six Parts and nineteen Tables, as summarised in the CBIC annual-return flyer (FAQ_annual-return-gstr-9_2019):
- Part I (Tables 1–3B) — basic details: financial year, GSTIN, legal and trade name.
- Part II (Tables 4–5) — outward supplies. Table 4 carries supplies on which tax is payable: B2C, B2B, zero-rated on payment of tax, SEZ supplies on payment, deemed exports, advances, inward reverse-charge supplies, and the credit notes, debit notes and amendments against them. Table 5 carries supplies on which tax is not payable: zero-rated and SEZ supplies without payment, supplies where the recipient pays under reverse charge, exempted, nil-rated and non-GST supplies.
- Part III (Tables 6–8) — credit. Table 6 breaks the GSTR-3B credit total (6A) into inputs, capital goods and input services, reverse-charge credit, imports, ISD credit, reclaims (6H) and credit taken through ITC-01, ITC-02 and ITC-02A. Table 7 captures reversals rule by rule: 7A Rule 37, 7B Rule 39, 7C Rule 42, 7D Rule 43, 7E §17(5), 7F and 7G transitional credit reversals, 7H other. Table 8 is the reconciliation engine — 8A auto-populated from the supplier-side statement, 8B from 6B and 6H, 8C credit of the year availed in the next year's returns, 8D the residual difference, 8E and 8F the lapse split, and 8G–8H IGST on imports.
- Part IV (Table 9) — tax actually paid as declared in the returns for the year.
- Part V (Tables 10–14) — transactions of the year declared or amended in the next year's returns: upward amendments, credit notes, ITC reversed in the next year, ITC of the year availed in the next year, and the differential tax paid.
- Part VI (Tables 15–19) — demands and refunds, composition and §143 job-work supplies, the HSN-wise outward and inward summaries, and late fee payable and paid.
FORM GSTR-9C mirrors this with five Parts and seventeen Tables: turnover reconciliation from the audited financial statement to the annual return (Tables 5–8), rate-wise tax-paid reconciliation (9–11), ITC reconciliation against books including the expense-wise breakdown in Table 14 (12–16), and additional liability payable in cash (17). GSTR-1, GSTR-3B and GSTR-9 for the year must all be filed before GSTR-9C can be.
Veritect Legal AI
Annual-return disputes almost never turn on Table 4 — they turn on Table 8D and Table 14. A ₹40 lakh 8D residual can be a genuine ineligible-credit exposure, a timing difference already covered by 8C, or an artefact of a supplier amending after the 8A cut-off, and the three have completely different consequences in a §73 notice. Veritect Legal AI holds the GSTR-9 and GSTR-9C instructions across every notified version alongside the reconciliation circulars, so a query such as "how should an FY 2023-24 Table 8D difference caused by a supplier's Q4 GSTR-1 amendment be explained in a scrutiny reply" resolves against the operative instruction text rather than a template.
Late fee, and the composite-period trap
Section 47(2) of the CGST Act charges ₹100 per day under the CGST Act plus ₹100 per day under the State or UT Act, capped at 0.25% + 0.25% = 0.50% of turnover in the State or Union territory. Notification 07/2023-Central Tax (CGST_07_2023) rationalised this from FY 2022-23 onwards:
| Aggregate turnover in the FY | Late fee | Cap |
|---|---|---|
| Up to ₹5 crore | ₹25 per day per Act | 0.02% of State/UT turnover |
| Above ₹5 crore up to ₹20 crore | ₹50 per day per Act | 0.02% of State/UT turnover |
| Above ₹20 crore | Uncapped §47(2) rate | 0.50% of State/UT turnover |
The same notification carried a one-time amnesty capping total late fee at ₹10,000 for FY 2017-18 to FY 2021-22 returns filed between 1 April and 30 June 2023 — a window that has closed.
The trap sits in the interaction between the two forms. Circular 246/03/2025-GST (CIR_246_2025) holds that where GSTR-9C is required, the §44 annual return is not complete until both GSTR-9 and GSTR-9C are furnished, so §47(2) late fee runs as one composite period from the due date to the later filing — it does not stop when GSTR-9 alone is filed. Notification 08/2025-Central Tax (CGST_08_2025) responded with an amnesty for any year up to FY 2022-23: late fee in excess of the amount payable up to the GSTR-9 filing date was waived where the pending GSTR-9C was filed by 31 March 2025, with no refund of late fee already paid.
The FY 2024-25 overhaul
Notification 13/2025-Central Tax (CGST_13_2025), effective 22 September 2025, rebuilt the credit and adjustment tables. Part III now splits ITC into 6A1 — credit of the preceding financial year availed in the current year, expressly excluding reclaims under Rules 37 and 37A — and 6A2 as net ITC, with difference J recomputed as I minus A2. New reversal items 7A1 (Rule 37A) and 7A2 were inserted, and item 6M was reworded to cover ITC-01, ITC-02 and ITC-02A other than GSTR-3B and TRAN forms. New item 8H1 captures IGST credit on imported goods availed in the next financial year, with difference I recomputed as G minus (H + H1). Part IV replaces the single aggregated ITC column with head-wise utilisation columns for central, State/UT, integrated tax and cess. Part V serials 10 to 14 were substituted to track April-to-October next-year adjustments filed by 30 November, with reclaimed Rule 37/37A credit routed to Table 6H rather than serial 13. On the GSTR-9C side, new items D1 and K-2 carve out §9(5) e-commerce-operator supplies, and a new Table 17 reports late fee payable and paid.
Where reconciliations fail
Four failure modes account for most annual-return notices. First, treating Table 8D as an error rather than a difference — the residual is frequently a timing gap already reported in 8C. Second, misclassifying reverse-charge inward supplies between Table 4 and Table 5. Third, attempting to claim missed credit through the annual return: additional liability can be declared and paid through FORM GST DRC-03 tagged "Annual Return", but credit cannot be claimed here — the §16(4) window is the only route. Fourth, under-reporting the HSN summaries in Tables 17 and 18 at the digit level prescribed for the taxpayer's turnover class.
FAQ
Q: Who must file FORM GSTR-9 and by when?
A: Section 44 of the Central Goods and Services Tax Act, 2017 (CGST Act) read with Rule 80 of the CGST Rules, 2017 requires every registered person to file the annual return by 31 December following the end of the financial year, filed GSTIN-wise rather than at PAN level. Five categories are excluded: Input Service Distributors, tax deductors under §51, tax collectors under §52, casual taxable persons and non-resident taxable persons. Both monthly and QRMP quarterly filers of GSTR-3B file the same FORM GSTR-9. Notification 15/2025-Central Tax (CGST_15_2025) continues the exemption for registered persons whose aggregate annual turnover does not exceed ₹2 crore.
Q: What is the difference between GSTR-9, GSTR-9A, GSTR-9B and GSTR-9C?
A: FORM GSTR-9 is the annual return for regular taxpayers filing GSTR-1 and GSTR-3B. FORM GSTR-9A was the composition-taxpayer annual return under §10 of the CGST Act and is not required from FY 2019-20 onwards, having been displaced by the annual FORM GSTR-4. FORM GSTR-9B is the annual statement for e-commerce operators collecting tax at source under §52. FORM GSTR-9C is the reconciliation statement between the audited annual financial statement and the annual return, required where aggregate turnover exceeds ₹5 crore under Rule 80(3). GSTR-9C was inserted into the Rules by Notification 49/2018-Central Tax (CGST_49_2018).
Q: Is GSTR-9C still certified by a Chartered Accountant?
A: No. Notification 30/2021-Central Tax (CGST_30_2021), effective 15 August 2021, substituted Rule 80 in full, set the reconciliation-statement threshold at ₹5 crore aggregate turnover, omitted Part B of FORM GSTR-9C — the auditor's certification — entirely, and replaced the verification clause with a taxpayer affirmation. From FY 2020-21 onwards GSTR-9C is a self-certified statement, so the accountability for reconciliation differences sits with the registered person, not with an external auditor certifying under the former §35(5) audit regime.
Q: What late fee applies if I file the annual return late?
A: Section 47(2) of the CGST Act charges ₹100 per day under the CGST Act plus ₹100 per day under the State or UT Act — ₹200 per day combined — capped at 0.25% plus 0.25%, that is 0.50%, of turnover in the State or Union territory. Notification 07/2023-Central Tax (CGST_07_2023) rationalised this from FY 2022-23 onwards: ₹25 per day per Act capped at 0.02% of State turnover for aggregate turnover up to ₹5 crore, and ₹50 per day per Act capped at 0.02% for turnover above ₹5 crore and up to ₹20 crore. Registered persons above ₹20 crore remain on the uncapped §47(2) figure.
Q: If I filed GSTR-9 on time but GSTR-9C late, does late fee run on the annual return?
A: Yes. Circular 246/03/2025-GST (CIR_246_2025) clarifies that where FORM GSTR-9C is required alongside FORM GSTR-9, the annual return under §44 of the CGST Act is not complete until both are furnished, so late fee under §47(2) runs as a single composite period from the due date until the later of the two filings — not separately for each form. Notification 08/2025-Central Tax (CGST_08_2025) provided a one-time amnesty: for any financial year up to FY 2022-23, late fee in excess of the amount payable up to the GSTR-9 filing date was waived if the pending GSTR-9C was filed by 31 March 2025, with no refund of late fee already paid.
Q: Can I claim missed input tax credit through the annual return?
A: No. Additional output liability for the financial year that was not declared in GSTR-1 or GSTR-3B can be declared in FORM GSTR-9 and paid through FORM GST DRC-03 tagged "Annual Return", but input tax credit cannot be claimed through the annual return. Missed credit is only recoverable inside the §16(4) window of the CGST Act — 30 November following the financial year — through a GSTR-3B, and is otherwise lost. Circular 124/43/2019-GST (CIR_124_2019) confirms the parallel point that reconciliation shortfalls found while preparing the annual return may be settled voluntarily through DRC-03 under §73.
Q: What changed in FORM GSTR-9 for FY 2024-25?
A: Notification 13/2025-Central Tax (CGST_13_2025) overhauled the form. Part III now splits ITC into item 6A1 — credit of the preceding financial year availed in the current year, excluding reclaims under Rules 37 and 37A of the CGST Rules — and 6A2 as net ITC, with the difference J recomputed as I minus A2. Reversal items 7A1 (Rule 37A) and 7A2 were added, and new item 8H1 captures IGST credit on imported goods availed in the next financial year, with difference I recomputed as G minus H plus H1. Part IV expands tax-paid reporting into head-wise ITC utilisation columns, and Part V serials 10 to 14 were substituted to track April-to-October next-year adjustments filed by 30 November.
Related on Veritect: GSTR-9 FY 2024-25 changes — 6A1/6A2 cross-year ITC split
Sources
Primary CBIC and Government of India sources relied on for this explainer:
- CBIC Tax Information Portal — notification and circular text: taxinformation.cbic.gov.in
- CBIC GST portal (archival, 2017–2022 instruments): cbic-gst.gov.in
- GST Council — GST annual return flyer and form structure: gstcouncil.gov.in
- CGST Act, 2017 — §§44, 47(2), 143, 148: indiacode.nic.in
- Gazette of India — notification publication: egazette.gov.in
Corpus anchors: CGST_49_2018, CGST_30_2019, CGST_47_2019, CGST_56_2019, CIR_124_2019, CGST_09_2020, CGST_79_2020, CGST_30_2021, CGST_31_2021, CGST_40_2021, CGST_10_2022, CGST_14_2022, CGST_07_2023, CGST_32_2023, CGST_14_2024, CGST_08_2025, CIR_246_2025, CGST_13_2025, CGST_15_2025, FAQ_annual-return-gstr-9_2019.
This explainer is general information on Indian central GST law and is not legal or tax advice. Verify the operative notification text, form version and due date for the financial year in question before filing.
Beyond this brief Preview
This article covers the framework. The full compliance picture includes the complete nineteen-table GSTR-9 instructions and the seventeen-table GSTR-9C reconciliation walkthrough as notified for each financial year, the verbatim Rule 80 text across its 2017, 2020 and 2021 versions, the full FY 2024-25 form-overhaul schedule from Notification 13/2025-Central Tax including every recomputed difference formula, the turnover-threshold notification chain year by year, and the late-fee amnesty conditions with their proviso text. Veritect Legal AI holds all twenty anchor instruments cited above in full text, supersession-tracked, so practitioners can resolve queries such as "which GSTR-9 optional fields were relaxed for FY 2019-20" or "how is composite-period §47(2) late fee computed where GSTR-9 was filed in January and GSTR-9C in the following November" against the operative sources rather than secondary summaries. Access through veritect.ai.