BCAS Urges Finance Ministry to Extend Due Date for Filing GSTR-9 and GSTR-9C Beyond Dec 31

Bombay Chartered Accountants’ Society (BCAS) has recently written a formal representation dated December 29, 2025, addressed to Smt. Nirmala Sitharaman, Honourable Minister of Finance; CBIC Chairman; GST Council Secretariat; Principal Chief Commissioner CGST & Central Excise, Mumbai Zone; and Shri Asheesh Sharma, Commissioner of State Tax.

The representation has highlighted the challenges faced by individuals in filing FORM GSTR-9 and GSTR-9C and hence, urged the desired authorities to extend the due date for the same.

In the present representation, BCAS tried drawing attention to its earlier representation dated December 11, 2025, which had emphasised the significant challenges faced while furnishing the Annual Return (Form GSTR-09) and Reconciliation Statement (GSTR-9C) for Financial Year 2024-25 (Assessment Year 2025-26). Therefore, the tax authorities were urged to extend the due dates for the same till December 31, 2025. Now, BCAS is trying to draw the tax authorities’ attention to another key issue.

Here is the list of a few issues highlighted by BCAS in its present representation:

1. Through Notification No. 13/2025-CT dated September 17, 2025, the GST Department had recently introduced a few changes in Forms GSTR-9 and GSTR-9C and improved the level of granularity and complexity in ITC reporting. The businesses and tax professionals are not familiar with these changes and will need time to understand them.

2. Preparing and filing Form GSTR-9C is fully dependent on the audited annual financial statements. This is because Form GSTR-9C is a reconciliation statement that requires matching the turnover and other details shown in the Annual Return (Form GSTR-9) with the figures given in the audited financial statements. Without the audited financial statements, this reconciliation cannot be done properly.

3. The due date for furnishing the Annual Return (Form GSTR-09) and Reconciliation Statement (GSTR-9C) for FY 2024-25, i.e., December 31, 2025, overlaps with several other compliance deadlines. The last date to complete adjudication under section 73 of the CGST Act for FY 2021-22 and under section 74 for FY 2018-19 is also the same, i.e., December 31, 2025. Hence, this is creating an extra burden on the heads of tax professionals and businesses.

In conclusion to the aforesaid emphasised issues, the Bombay Chartered Accountants’ Society (BCAS) has requested the tax authorities to further extend the date for filing FORM GSTR-9 and GSTR-9C beyond December 31, 2025.