GSTR-9 and GSTR-9C for FY 2025-26: Who Files What, and by When
The GST annual return for FY 2025-26 is due by 31 December 2026. It can't be revised once filed, and the department reads it alongside your GSTR-1, GSTR-3B and GSTR-2B data. This guide explains who must file, which tables cause the most trouble, and the reconciliations to finish before you start.
Why it matters
The Annual Return Is Your Final Word on the Year
GSTR-9 pulls together twelve months of returns into one statement. Because it can't be amended afterwards, an error here is an error you live with.
There is no revised GSTR-9
Once submitted, the annual return is final. Corrections mean paying through DRC-03 rather than editing the return.
It is a scrutiny starting point
Officers compare GSTR-9 with GSTR-1, GSTR-3B, GSTR-2B, your e-way bills and your income-tax turnover.
It is your last chance to pay up
Short-paid tax found during the year-end review can be paid in DRC-03 with interest, before it becomes a notice.
Returns expire after three years
A return not filed within three years of its due date can no longer be filed at all, and that bar is now being enforced on the portal.
Who has to file
| Aggregate turnover in FY 2025-26 | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional | Not required |
| Above ₹2 crore and up to ₹5 crore | Mandatory | Not required |
| Above ₹5 crore | Mandatory | Mandatory, self-certified |
A few points that are easy to get wrong:
- Composition dealers file GSTR-9A, not GSTR-9. If you moved between the composition and regular schemes during the year, you file for each period separately.
- One return per GSTIN. If you hold registrations in both Gujarat and another state, each files its own GSTR-9, but the turnover test is applied on your PAN as a whole.
- Not required from input service distributors, casual taxable persons, non-resident taxable persons, and persons paying TDS under Section 51.
- Cancelled during the year? If your registration was active for any part of FY 2025-26, you still file for that period. Cancellation doesn't remove the obligation.
- GSTR-9C is self-certified. Since FY 2020-21 it no longer needs a CA's audit certificate. It is still a reconciliation statement, and the figures have to stand up to scrutiny.
If your turnover is under ₹2 crore you can skip GSTR-9, and most small traders do. Filing anyway can be worth it if you had a lot of amendments, credit notes or ITC reversals during the year, because the annual return lets you set the year's position out clearly in one place.
Working out aggregate turnover correctly
Aggregate turnover is computed on your PAN across India, not on a single GSTIN. It includes:
Counts towards turnover
- All taxable supplies, including branch transfers between your own GSTINs
- Exempt and nil-rated supplies
- Exports and supplies to SEZ units
- Turnover of all your GSTINs across states, added together
Left out
- CGST, SGST, IGST and cess charged on your invoices
- Inward supplies on which you paid tax under reverse charge
- Value of goods returned, to the extent credit notes were issued
This trips up businesses with a second registration. A Vadodara firm with ₹3.5 crore of turnover in Gujarat and ₹2 crore in Maharashtra has an aggregate turnover of ₹5.5 crore, so GSTR-9C becomes mandatory for both registrations, even though neither one crosses ₹5 crore on its own.
The deadline before the deadline: 30 November 2026
The annual return reports what happened. It can't fix it. Anything that needs correcting for FY 2025-26 has to be done in your monthly returns by the earlier of the return for October 2026 or the date you file the annual return, which in practice means 30 November 2026. After that:
- Input tax credit for FY 2025-26 invoices can no longer be claimed
- Credit notes for FY 2025-26 supplies can no longer be reported with a tax adjustment
- Amendments to FY 2025-26 invoices in GSTR-1 are no longer possible
Working backwards from 30 November means reconciling books against GSTR-2B in October. Businesses that wait until December find missing credit they can no longer claim, which is a permanent cost.
Four reconciliations to finish first
Books turnover against GSTR-1
Compare sales in your accounts with the outward supplies reported through the year. Look for invoices raised in March 2026 but reported in April, exports, and supplies to related parties.
GSTR-1 against GSTR-3B
Tax declared in GSTR-1 should match what you paid in GSTR-3B. Since July 2025, Table 3.1 and 3.2 of GSTR-3B are locked to your GSTR-1 figures, so any difference in earlier months needs explaining through GSTR-1A.
ITC in books against GSTR-2B
Credit is available only where the supplier has reported the invoice and it appears in your GSTR-2B. List what's in your books but not in 2B, and follow up with those suppliers before November.
Reverse charge and blocked credit
Check RCM on goods transport, legal fees, director remuneration and imports, and confirm that credit blocked under Section 17(5) was actually reversed.
Tables that cause the most trouble
Table 8A: auto-filled ITC
This is populated from your GSTR-2B, not GSTR-2A. The difference between 8A and the credit you actually claimed has to be explained line by line, so keep your reconciliation working ready.
Table 6: ITC break-up
Credit has to be split between inputs, input services and capital goods. Most accounting software doesn't tag this by default, so it usually has to be built from the purchase register.
Tables 10 to 14: cross-year entries
Transactions of FY 2025-26 that you declared in the FY 2026-27 returns go here. Missing them is the single most common reason the annual return doesn't tie to the monthly ones.
Table 17: HSN summary of outward supplies
Reporting is at four digits where turnover is up to ₹5 crore and six digits above that. Clean up your item master before you start, because mismatched HSN codes are a frequent query.
Table 7: ITC reversals
Reversals under Rules 37, 42 and 43 and Section 17(5) are reported separately. Rule 37 covers credit on invoices you haven't paid within 180 days, which is often overlooked.
Table 9 and the payment columns
Additional liability identified during the year-end review is paid in cash through DRC-03. It cannot be set off against input tax credit.
Late fees and time limits
| Aggregate turnover | Late fee for GSTR-9 | Maximum |
|---|---|---|
| Up to ₹5 crore | ₹50 per day (₹25 CGST + ₹25 SGST) | 0.04% of turnover in the state (0.02% each) |
| Above ₹5 crore and up to ₹20 crore | ₹100 per day (₹50 CGST + ₹50 SGST) | 0.04% of turnover in the state (0.02% each) |
| Above ₹20 crore | ₹200 per day (₹100 CGST + ₹100 SGST) | 0.50% of turnover in the state (0.25% each) |
GSTR-9C attracts its own late fee where it is filed after the annual return. Beyond the fee, two consequences matter more: interest at 18% a year on tax paid late, and the three-year bar, after which the return simply cannot be filed and the credit is gone.
This guide is general information on Indian tax and corporate law as it stood on 11 September 2026, and is not advice for any particular case. Rules, due dates and forms change, and how they apply depends on your facts. Please confirm the current position before acting, or speak to a qualified professional.
Who this applies to
Annual Return Situations in Vadodara
The reconciliation work differs a good deal by the kind of business you run.
Manufacturers with job work
Units in Makarpura, Por and Nandesari sending goods for job work need ITC-04 records and job-work returns to line up with the annual return.
Exporters and SEZ suppliers
Zero-rated supplies, LUT coverage and refund claims all have to agree with the turnover reported in Table 5.
Traders and distributors
High invoice volumes mean HSN summaries and credit notes take the longest. Start the Table 17 clean-up early.
Service providers
Reverse charge on legal fees, goods transport and director remuneration, and Rule 42 reversals where you have exempt income, need checking.
Frequently asked questions
Answers to Your GST Annual Return Questions
What is the GSTR-9 due date for FY 2025-26?
31 December 2026, for both GSTR-9 and GSTR-9C, unless the CBIC notifies an extension. Corrections to FY 2025-26 entries have to be made in your monthly returns by 30 November 2026.
My turnover is ₹1.8 crore. Do I have to file GSTR-9?
No. Filing is optional where aggregate turnover is up to ₹2 crore. Check the figure on your PAN across all GSTINs and include exempt and nil-rated supplies, because the total is often higher than expected.
Does GSTR-9C still need a Chartered Accountant's certificate?
No. Since FY 2020-21 it is a self-certified reconciliation statement filed by the taxpayer. Many businesses still have it prepared professionally, because the reconciliation is compared against monthly returns during scrutiny.
Can I revise GSTR-9 after filing it?
No. There is no revised annual return. If you find an error later, the tax is paid through DRC-03 with interest. This is why the reconciliations should be finished before filing.
I missed claiming ITC on some FY 2025-26 invoices. Can I still claim it?
Only until 30 November 2026, through your GSTR-3B. The annual return cannot be used to claim credit you didn't take in the monthly returns. After that date the credit lapses.
What is the late fee if I file after 31 December?
₹50 a day where aggregate turnover is up to ₹5 crore, ₹100 a day between ₹5 crore and ₹20 crore, and ₹200 a day above ₹20 crore, subject to a cap linked to your turnover in the state. Interest at 18% a year applies to any tax paid late.
Annual Return Due 31 December? Start the Reconciliation Now.
Share your GST login or your books, and we'll reconcile GSTR-1, GSTR-3B and GSTR-2B, flag credit you can still claim before 30 November, and prepare the annual return with you.
C M Patel & Company, Chartered Accountants
204, Pavan Complex, Jetalpur Road, Jetalpur, Vadodara, Gujarat 390007
Phone +91 99740 37318 · Email info.cmpatelandcompany@gmail.com
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