GST - annual compliance guide

Last reviewed: 25 September 2026. The GST annual return is where a whole year of sales, input tax credit and tax paid is pulled together and reconciled - and because it cannot be revised, mismatches here are a leading cause of GST notices. This guide covers who must file GSTR-9 and GSTR-9C, the thresholds and due date, what each contains, how to reconcile before filing, and how to handle any extra liability.

At a glance

GSTR-9Mandatory above Rs 2 crore aggregate turnover.
GSTR-9CSelf-certified reconciliation, above Rs 5 crore.
Due date31 December of the next year (FY 2025-26 by 31 Dec 2026).
No revisionThe return cannot be revised - reconcile first.

What GSTR-9 and 9C contain

GSTR-9 consolidates your outward supplies (from GSTR-1), tax paid (from GSTR-3B) and input tax credit (from GSTR-2B) for the year, along with a summary of HSN codes for inward and outward supplies. GSTR-9C then reconciles the turnover and tax as per your books/annual accounts with what was declared in the GST returns, and requires you to explain any differences.

Thresholds and who is exempt

ReturnWho files
GSTR-9Regular taxpayers, aggregate turnover > Rs 2 crore. Up to Rs 2 crore, filing is exempted under Notification 15/2025-Central Tax, which applies from FY 2024-25 onwards
GSTR-9CAggregate turnover > Rs 5 crore (self-certified)
GSTR-4 (annual)Composition taxpayers: GSTR-4 by 30 June following the year; GSTR-9 not required (GSTR-9A has been dispensed with since FY 2019-20)
Not requiredCasual/NR taxable persons, ISD, TDS/TCS deductors

Key tables in GSTR-9, and what each needs

TableWhat it reportsReconcile against
4Outward supplies on which tax is payable, including advances and inward supplies liable to reverse chargeGSTR-1 and books, including RCM on imported services
5Outward supplies on which no tax is payable (exports under LUT, exempt, nil-rated, non-GST)GSTR-1 and the sales register
6ITC availed in GSTR-3B, split by type (inputs, capital goods, input services, imports, RCM, ISD)GSTR-3B and the purchase register
8A-8DITC as per the auto-drafted statement (Table 8A) compared with ITC availed; the difference is explained hereGSTR-2B as finalised after the Invoice Management System (IMS) actions
17/18HSN-wise summary of outward and inward suppliesItem master and GSTR-1 HSN tables

The form was revised from FY 2024-25: Table 8A now draws from GSTR-2B rather than GSTR-2A, and additional rows separate ITC relating to the previous year that was claimed in the current year. Use the current version of the form on the portal rather than last year's working file.

Reconcile these before you file

  • Outward turnover in books vs GSTR-1 vs GSTR-3B.
  • ITC claimed in GSTR-3B vs available in GSTR-2B; reverse ineligible or blocked credit.
  • Tax, interest and any DRC-03 payments made during the year.
  • HSN-wise summary of inward and outward supplies.
  • ITC for FY 2025-26 can be claimed only up to 30 November 2026 (Section 16(4)). Credit missed in the monthly returns cannot be picked up through GSTR-9.

Indian subsidiaries of foreign groups: check tax paid under reverse charge on services imported from the parent or group companies, and reconcile cross-charges or ISD distributions of common costs, because these are the lines GSTR-9C most often fails to tie to the books.

Worked example: a reconciliation for FY 2025-26

ItemAmount
Taxable turnover as per booksRs 6,40,00,000
Taxable turnover in GSTR-1Rs 6,35,00,000
Taxable turnover in GSTR-3BRs 6,32,00,000
Difference between books and GSTR-3BRs 8,00,000, traced to a credit sale in October 2025 left out of both returns (Rs 5,00,000) and a debit note reported in GSTR-1 but not in GSTR-3B (Rs 3,00,000)
Tax short-paid at 18%Rs 1,44,000
Interest at 18% p.a. under Section 50(1), from the October 2025 GSTR-3B due date (20 November 2025) to payment on 15 December 2026, about 390 daysAbout Rs 27,700
Paid through DRC-03, in cashRs 1,44,000 tax + about Rs 27,700 interest

The Rs 8,00,000 is reported in GSTR-9 as additional liability and explained in GSTR-9C against the books. Paying it before filing, rather than waiting for a notice, keeps the interest to the period actually elapsed and avoids penalty proceedings on a known shortfall. If the same review had found ITC in GSTR-3B that was not in GSTR-2B, that credit would be reversed through DRC-03 with interest as well.

Paying additional liability

If reconciliation throws up short-paid tax, pay it through Form DRC-03 in cash, with interest under Section 50. Remember you cannot claim missed ITC in GSTR-9 - the annual return only discloses, it does not open a fresh window to take credit.

Late fee for late filing

Aggregate turnover in the yearLate fee per day (CGST + SGST)Maximum
Up to Rs 5 croreRs 50 (Rs 25 + Rs 25)0.04% of turnover in the State
Rs 5 crore to Rs 20 croreRs 100 (Rs 50 + Rs 50)0.04% of turnover in the State
Above Rs 20 croreRs 200 (Rs 100 + Rs 100)0.5% of turnover in the State

These tiers come from Notification 7/2023-Central Tax. Where GSTR-9C is also required, Circular 246/03/2025-GST says the late fee runs from the GSTR-9 due date until both GSTR-9 and GSTR-9C are filed, rather than being charged twice. Check the current position with us before relying on it for a return that is already late.

Frequently asked questions

Who is required to file GSTR-9?

Every regular GST-registered taxpayer whose aggregate turnover in the financial year exceeds Rs 2 crore must file the annual return GSTR-9. Below Rs 2 crore it is optional.

Who must file GSTR-9C as well?

Taxpayers with aggregate turnover above Rs 5 crore must also file GSTR-9C, the reconciliation statement between the annual return and the audited/annual accounts.

Is CA certification required for GSTR-9C?

No. GSTR-9C is now self-certified by the taxpayer; the earlier mandatory certification by a CA or CMA has been removed, though many businesses still take professional help to reconcile.

What is the due date?

The annual return for a financial year is due by 31 December of the following year - so FY 2025-26 is due by 31 December 2026 (FY 2024-25 was due 31 December 2025).

Can GSTR-9 be revised once filed?

No. GSTR-9 cannot be revised, which is exactly why every figure must be reconciled before you file.

Can I claim missed input tax credit through GSTR-9?

No. GSTR-9 is only a disclosure return; you cannot claim additional ITC in it. Missed ITC must be claimed in the monthly returns within the time limit under Section 16(4) — for FY 2025-26, only up to 30 November 2026 — not in the annual return.

How do I pay any additional tax found while filing?

Any additional liability identified in the annual return is paid through Form DRC-03, in cash (not from the ITC ledger), with interest under Section 50.

Do composition dealers file GSTR-9?

No. Composition taxpayers file GSTR-4 as their annual return, due by 30 June following the financial year; GSTR-9 is not required, and GSTR-9A has been dispensed with since FY 2019-20. Casual taxable persons, non-resident taxable persons, input service distributors and TDS/TCS deductors are not required to file GSTR-9.

What is the late fee for GSTR-9?

Under Notification 7/2023-Central Tax the late fee depends on aggregate turnover (CGST and SGST combined): up to Rs 5 crore, Rs 50 per day capped at 0.04% of turnover in the State; Rs 5-20 crore, Rs 100 per day capped at 0.04%; above Rs 20 crore, Rs 200 per day capped at 0.5%. Where GSTR-9C is also required, Circular 246/03/2025-GST treats the late fee as running from the GSTR-9 due date until both forms are filed, rather than as two separate fees; check the current position before relying on it.

What are the most common reconciliation errors?

Turnover differences between books, GSTR-1 and GSTR-3B; ITC claimed in 3B but not reflected in 2B; unreversed ineligible or blocked credit; and mismatches in tax paid versus tax payable.

Getting your GST annual return right?

We reconcile GSTR-1, 3B and 2B against your books, prepare GSTR-9 and 9C, and clean up mismatches before filing.

GSTR-9 & 9C Annual Return FilingGST Registration & FilingGST Notice Handling
Still have doubts?

Talk to CA Somesh Chandak & Associates - we reconcile and prepare your GST annual return for filing.

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Disclaimer: This article is for general guidance only and is not a substitute for advice on your specific facts and the latest law. Please consult before filing.