GSTR-9/9C Filing Begins: Experts Flag Strict ITC Reconciliation Ahead

The filing window for GSTR-9 and GSTR-9C for FY 2024-25 is currently open. Tax professionals are reviewing new GSTN FAQs to understand their impact on annual compliance.

Clarifications on Input Tax Credit (ITC) reporting, especially in Tables 6, 7, 8, and the new 8H1, are expected to influence how businesses approach reconciliation.

Sandeep Sehgal, Partner–Tax at AKM Global, said the FAQs clear up old doubts but also introduce new compliance checkpoints.

“The granular instructions on how to classify ITC reversals and reclaims under Rules 37 and 37A depending on whether they relate to the current or previous financial year will require careful ledger tracking,” Sehgal noted. “Even the variance between Table 8A as shown online versus in Excel needs manual intervention using the supporting document download utility.”

Expert’s perspective

The following are some key points from expert’s perspective:

• The new Table 8H1 may require businesses importing goods to make additional disclosures if ITC is deferred to the next financial year.
• The realignment of Table 6M, which now combines ITC from Forms ITC-01, 02, and 02A, could make reporting easier for companies undergoing transfers or reorganisations, though proper data classification is still needed.
• Table 17, which deals with late fees in GSTR-9C, aims to standardise computation; however, many filers remain unsure if the portal’s auto-calculation will override manual entries.
• Cross-year Input Tax Credit (ITC) in Table 13 where ITC for FY 2024-25 claimed in Financial Year 2025–26 should be reported and also remains a common source of mismatches with GSTR-2B.

Auto-populated ITC figures now reflect FY 2024-25 filings and changes up to October 2025. Experts warn businesses to start ledger alignment immediately rather than leaving it until the deadline.

“Even though the forms are technically the same, the disclosures are becoming increasingly forensic,” Sehgal said. “This year’s annual return will not be a mere summarisation exercise – it’s a test of consistency between GSTR-3B, GSTR-2B and internal books.”