The Annual Return (GSTR-9) and
Reconciliation Statement (GSTR-9C) filing for Financial Year 2024-25 requires
meticulous attention. While the filing thresholds remain, the government has
continued to grant substantial relaxations, simplifying the reporting
requirements for numerous tables.
This detailed breakdown focuses on the
purpose of each critical table and the expected simplifications (often provided
through annual CBIC notifications) for the FY 2024-25 filing cycle.
Part A: Detailed Analysis of GSTR-9
(Annual Return)
GSTR-9 is the annual consolidation of
all monthly/quarterly returns (GSTR-1 and GSTR-3B) filed during the financial
year.
|
Table No. |
Heading/Section |
Purpose of the Table |
Expected Simplification for FY
2024-25 |
|
Part II |
Details of Outward and Inward
Supplies declared during the financial year |
Summarizes all outward supplies and
inward supplies liable to Reverse Charge (RCM). |
|
|
4 |
Details of advances, outward and
inward supplies made during the financial year on which tax is payable. |
To report the gross turnover and tax
liability declared in GSTR-1 and GSTR-3B. |
Consolidation Allowed (Major
Relief): Taxpayers are usually allowed to report all details (e.g.,
zero-rated, exempted, non-GST supplies, and supplies to unregistered persons)
under the single, most relevant column (e.g., Supplies on which tax is
payable), eliminating the need for minute bifurcation. |
|
5 |
Details of Outward Supplies made
during the financial year on which tax is not payable. |
To report non-taxable supplies,
including exempted, nil-rated, non-GST supplies, and supplies where RCM
applies to the recipient. |
Consolidation Allowed: Similar
to Table 4, taxpayers are often permitted to club various
exempted/non-taxable supplies under the "Exempted" or "Nil
Rated" heads, simplifying detailed breakup. |
|
Part III |
Details of ITC declared during the
financial year |
Focuses on the Input Tax Credit
availed, reversed, and reconciled. |
|
|
6 |
Details of ITC availed during the
financial year. |
Reports the total ITC claimed in
GSTR-3B throughout the year, bifurcated by type (Inputs, Input Services,
Capital Goods). |
ITC Consolidation (Massive Relief):
Taxpayers are typically allowed to report the entire eligible ITC under the “All
Other ITC” head (other than RCM), removing the tedious requirement to
bifurcate ITC into Inputs, Input Services, and Capital Goods. |
|
7 |
Details of ITC Reversed and
Ineligible ITC. |
Discloses all ITC reversals mandated
by Rules (e.g., Rule 42/43) and ineligible ITC (e.g., blocked credit u/s
17(5)). |
Reversal Consolidation:
Taxpayers are generally allowed to report the total ITC reversed in GSTR-3B
under the “Other Reversals” head, eliminating the need for a
rule-wise/section-wise breakup. |
|
8 |
Other ITC Related Information. |
Reconciles ITC as per GSTR-2A/2B
(System generated) with ITC actually claimed in GSTR-3B. |
Auto-Population & Critical
Check: Table 8A is auto-populated from GSTR-2A/2B data. This
table is a crucial audit point and is NOT simplified. Taxpayers must
reconcile any difference (Table 8D). |
|
Part V |
Details of Amendments for the
supplies of the previous financial year declared in returns of the current
financial year |
Reports transactions of FY 2024-25
that were declared/adjusted in returns of the subsequent year (April to
October 2025). |
|
|
10 & 11 |
Supplies/Tax reported in next
financial year. |
Reports outward supplies/tax paid
pertaining to FY 2024-25 but declared in GSTR-1/GSTR-3B of April-Oct 2025. |
No Simplification: These
tables require accurate reporting as they are essential for reconciling the
current year's turnover with subsequent returns. |
|
12 & 13 |
ITC Reversals and ITC availed in the
next financial year. |
Reports ITC reversals (Table 12) and
eligible ITC availed (Table 13) in the April-Oct 2025 period, pertaining to
FY 2024-25. |
No Simplification: These
are critical reconciliation points and must be accurately reported based on
the statutory cut-off dates. |
|
17 |
HSN Wise Summary of Outward
Supplies. |
Requires detailed HSN summary of
outward supplies. |
Exemption/Relaxation based on
Turnover: The requirement for detailed HSN reporting is usually made
optional for taxpayers with AATO up to ₹5 crore or simplified for others
(e.g., reporting only the top HSNs). |
Part B: Detailed Analysis of GSTR-9C
(Reconciliation Statement)
GSTR-9C reconciles the data reported
in GSTR-9 with the Audited Financial Statements, which is mandatory for
turnover exceeding ₹5 Crore.
|
Table No. |
Heading/Section |
Purpose of the Table |
Expected Simplification/Key Feature
for FY 2024-25 |
|
Part A |
Reconciliation of Turnover |
Reconciles the total turnover as per
the Annual Financial Statement with the turnover declared in GSTR-9. |
|
|
5 |
Reconciliation of Gross Turnover. |
Starting with the turnover from the
Audited Financial Statement, adjustments are made for non-GST income,
inter-State stock transfers, etc., to arrive at the GST-declared turnover. |
No Simplification: This is
the core reconciliation of the form. Every difference (Table 5B to 5N)
must be accurately identified and justified with a reason. |
|
Part B |
Reconciliation of Tax Payable and
Paid |
Focuses on the tax liability
differences arising from the turnover reconciliation. |
|
|
9 |
Reconciliation of Tax Payable. |
Reconciles the tax liability based
on the reconciled turnover with the liability already declared in GSTR-9. |
No Simplification: Any
additional liability identified here must be paid through Form GST DRC-03. |
|
Part C |
Reconciliation of ITC |
Reconciles the total ITC reported in
GSTR-9 with the ITC recorded in the Audited Financial Statement (Books of
Accounts). |
|
|
12 |
Reconciliation of Net ITC. |
Reconciles the total ITC claimed in
GSTR-9 with the amount debited to the expense/asset accounts in the books. |
No Simplification: This is
a crucial check. Differences (e.g., ITC on blocked credit booked as expense)
must be properly classified and justified. |
|
14 |
Reconciliation of ITC availed on
expenses. |
Detailed reconciliation of ITC
availed on various expenses (e.g., raw material, maintenance, utilities). |
Optional Detail Breakup:
Taxpayers are often permitted to report the entire difference in ITC
reconciliation under the “All Other ITC” column, avoiding the detailed
expense-head-wise breakup (Raw Material, Services, Capital Goods, etc.). |
|
Certification |
Verification by Taxpayer |
Certification of the correctness of
the statement and reconciliation. |
Self-Certification (Major Policy
Change): For FY 2024-25, GSTR-9C is required to be self-certified
by the taxpayer (owner/director/partner). The mandatory requirement for a
CA/CMA certificate has been done away with. |
💡 Strategic
Takeaways for FY 2024-25 Filing
- Embrace Consolidation:
Utilize the relaxations in GSTR-9 (Tables 4, 5, 6, 7) to report aggregated
data, but ensure that the aggregated figures still reconcile with the data
in your GSTR-3B.
- Focus on Adjustments (Part V):
Since many compliance details (GSTR-1, GSTR-3B) are simplified, the focus
of future scrutiny will shift heavily to Tables 10 to 13 of GSTR-9,
which deal with the reconciliation of the current year's transactions
reported in the succeeding year.
- Self-Certification Responsibility: The
removal of the CA/CMA audit for GSTR-9C places the entire responsibility
of accuracy on the taxpayer. The self-certification in GSTR-9C is a legal
declaration, making meticulous internal reconciliation more important than
ever.
- Prioritize Payment (DRC-03): Any
undisclosed tax liability identified during the GSTR-9/9C process must be
immediately paid through Form GST DRC-03 before the final
submission of the annual returns.

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