TL;DR: If your aggregate turnover for FY 2025-26 (1 April 2025 to 31 March 2026) is above ₹2 crore, you file GSTR-9 by 31 December 2026. Above ₹5 crore, you also file a self-certified GSTR-9C, and the return counts as filed only when both are in. Under ₹2 crore you are exempt. Reconcile books against GSTR-1, GSTR-3B and GSTR-2B now, pay any shortfall through DRC-03 before you file, and do not file GSTR-9 before you have claimed all eligible credit, because the section 16(4) cut-off is the earlier of 30 November 2026 or your GSTR-9 filing date. There is no revision after you file.
GSTR-9 and GSTR-9C for FY 2025-26 are due on Thursday, 31 December 2026, which is 76 days from today, 16 October. Notification 15/2025-Central Tax exempts registered persons with aggregate turnover up to ₹2 crore for FY 2024-25 onwards[1], and Rule 80(3) requires the GSTR-9C reconciliation only above ₹5 crore[2]. The late fee for missing the date runs per day, for the days until the complete return is filed[3]. This post covers who files what, which numbers come pre-filled and which you can edit, a table-by-table checklist, the 2023 late fee slabs, interest on additional tax, a worked ₹1.3 lakh mismatch, and a dated calendar to 31 December.
Who must file GSTR-9, GSTR-9C or neither
Section 44 of the CGST Act requires every registered person except specified classes to file an annual return. Notification 15/2025-Central Tax, dated 17 September 2025, uses the first proviso to section 44(1) to exempt a registered person whose aggregate turnover in a financial year is up to ₹2 crore, "in respect of filing of annual return for the financial year 2024-25 onwards"[1]. That wording means FY 2025-26 is covered without a fresh notification. The exemption is per year and tied to that year's turnover, so check FY 2025-26 turnover, not last year's.
| Aggregate turnover FY 2025-26 | GSTR-9 | GSTR-9C | Basis |
|---|
| Up to ₹2 crore | Exempt | Not required | Notification 15/2025-CT[1] |
| Above ₹2 crore, up to ₹5 crore | Required | Not required | Section 44(1); Rule 80(3)[2] |
| Above ₹5 crore | Required | Required, self-certified | Rule 80(3), as substituted by Notification 30/2021-CT[2] |
| Composition taxpayer | GSTR-4 annual return, not GSTR-9 | Not required | GSTN treats GSTR-4 as replacing GSTR-9A since FY 2019-20, though the Rule 80(1) proviso as substituted by Notification 30/2021 still names GSTR-9A. Verify the form on the portal |
Three points that trip people up.
The exemption removes the obligation; it does not remove GSTR-1 or GSTR-3B. A ₹1.8 crore business still files every monthly or quarterly return.
Aggregate turnover is PAN-wide across all GSTINs, and it includes exempt and export supplies. A business with two GSTINs of ₹1.2 crore each crosses ₹2 crore and both GSTINs file.
Since FY 2020-21 the GSTR-9C is a self-certified statement, not a CA-audited one. A chartered accountant is no longer mandatory, though many firms still sign off before the owner does.
The due date and what is open on the portal
The FY 2025-26 due date is 31 December 2026, the statutory pattern for every year since the form began. GSTN Advisory No. 677 (reported dated 13 October 2026) says filing has been enabled with effect from 8 October 2026; another report says 10 October[4]. The advisory page itself sits behind a CAPTCHA, so treat the exact day as reported, not confirmed. The prerequisite is that every FY 2025-26 GSTR-1 and GSTR-3B is filed. Check Services > Returns > Annual Return on the portal before you plan around it. Plan for 31 December.
Where GSTR-9C is required, CBIC Circular 246/03/2025-GST makes the annual return "complete" only when both forms are filed[3]. Filing GSTR-9 on 30 December and GSTR-9C on 15 January means late fee runs for 15 days, from the due date to the date of the later form. The circular spells out both cases: the date of GSTR-9 if GSTR-9C is filed with it, or the date of GSTR-9C if filed later[3].
What is auto-populated and what you can edit
The portal pre-fills much of GSTR-9 from your filed returns. Per the commercial guides I checked, which cite GSTN's FAQs, Tables 4, 5, 6, 8 and 9 are partly drawn from GSTR-1, GSTR-1A, IFF, GSTR-2B and GSTR-3B, and the figures can be edited[5]. Table 8A comes from GSTR-2B and Table 8B from Table 6B[5]. The practical rule: the pre-fill is a starting point, not an answer. If your books say ₹8.42 crore and the portal says ₹8.38 crore, you do not accept the portal. You find out why.
Because GSTR-2B reflects your Invoice Management System actions, an invoice you rejected in IMS will not feed Table 8A. That is one reason the sibling post on the credit cut-off matters here: read the GST ITC deadline guide for 30 November 2026 before you touch Tables 6 and 8.
Form changes that came in with FY 2024-25
Secondary sources disagree on the year each change started, so treat this list as a prompt to open the live form.
Table 6A1 captures ITC of the preceding year claimed in the current year's GSTR-3B, excluding Rule 37/37A reclaims, which belong in Table 6H[5].
Table 7A1 records ITC reversed under Rule 37A where the supplier had not filed GSTR-3B[5].
Table 8H1 takes IGST on current-year imports that you availed in the next year, instead of Table 6E[5].
Table 8C was narrowed to ITC that appeared in GSTR-2B but you did not claim, plus, per GSTN FAQ summaries, invoices the seller uploaded between April and October of the next year[6].
Rate-wise lines need attention because FY 2025-26 straddles the 22 September 2025 rate restructuring, so Tables 9 to 11 and 17 may need two rate sets for the same HSN[4].
Table-by-table checklist
This is the working order I would use. The source column says where each number should come from. The mandatory-versus-optional split below is for FY 2024-25 as listed by StudyCafe[7]. I found no FY 2025-26 notification changing it, but the portal form for your year is the final word.
| GSTR-9 table | What goes in | Source to reconcile with | Status (FY 2024-25 pattern) |
|---|
| 4 (A to G, I to L) | Outward taxable supplies, exports, SEZ, RCM, advances, credit and debit notes, amendments | GSTR-1, GSTR-1A, GSTR-3B; books | Mandatory |
| 5 (A to F) | Exempt, nil-rated, non-GST outward supplies | GSTR-1, GSTR-3B Table 3.1 | Mandatory |
| 5H to 5K | Credit and debit note adjustments in the outward block | Can be folded into 5A to 5F | Optional |
| 6 (A to M) | ITC availed: inputs, services, capital goods, imports, ISD, 6A1 and 6H reclaims | GSTR-3B Table 4, GSTR-2B, purchase register | Mandatory |
| 7 (A to G) | ITC reversed and ineligible, incl. Rule 37, 37A, 42, 43, section 17(5) | GSTR-3B Table 4B; ITC reversal ledger | Mandatory |
| 8 (A to K) | ITC per GSTR-2B vs availed vs ineligible; carryover 8C | GSTR-2B for all 12 months plus April to October of the next year | Mandatory |
| 9 | Tax payable and tax paid, cash vs ITC, by head | GSTR-3B Table 6.1; electronic ledgers | Mandatory |
| 10 to 11 | FY 2025-26 supplies and credit/debit notes reported in April to November 2026 returns | GSTR-1 and 3B filed through November 2026 | Mandatory |
| 12 to 13 | Reversal of FY 2025-26 ITC, and FY 2025-26 ITC availed, in GSTR-3B for April to November 2026 (or the GSTR-9 filing date if earlier) | GSTR-3B April to November 2026 | Check form (sources conflict on whether mandatory) |
| 14 | Differential tax paid on 10 and 11 | DRC-03 or GSTR-3B | Mandatory where applicable |
| 15 to 16 | Demands and refunds; supplies received from composition dealers, deemed supply, goods on approval | Refund and order register | Optional |
| 17 | HSN summary of outward supplies | GSTR-1 Table 12 | Mandatory |
| 18 | HSN summary of inward supplies | Purchase register | Optional |
| 19 | Late fee payable and paid | Electronic cash ledger | Computed by portal |
Table 10 and 11 deserve extra care. A sales invoice dated 28 March 2026 that you add to GSTR-1 in May 2026 belongs in Table 10 of the FY 2025-26 return, not in Table 4. Leave Part V (Tables 10 to 14) blank when it should not be, and the annual return shows a false position against your filed monthly returns[5].
HSN digits in Table 17
Notification 78/2020-Central Tax (effective 1 April 2021) sets the HSN digits on tax invoices by preceding-year turnover: 4 digits up to ₹5 crore, 6 digits above[8]. Table 17 is reported on the same 4/6-digit split; the portal validation enforces it. The B2B-only relaxation for smaller filers comes from secondary guides[7], so check the live form instructions. The HSN code finder gives the 6 and 8 digit code and the current rate, and the GSTIN validator catches typos in the vendor list you will need for Table 8.
GSTR-9C: what the reconciliation statement asks
Above ₹5 crore, GSTR-9C reconciles audited or book turnover against the GSTR-9 figure in Part II, and ITC per books against ITC per GSTR-9 in Part III. Per StudyCafe's list for FY 2024-25, Tables 5A, 7A to 7F, 9A to 9Q and 12A to 12D are mandatory; 5B to 5O (foldable into 5O) and 14 are optional[7].
Late fee under section 47(2) and Notification 07/2023
The default late fee under section 47(2) is ₹100 a day for the period of default under the CGST Act, with an equal SGST amount, capped at a quarter of one percent of turnover in the State or Union territory under each Act. I could not fetch the Act's text from a primary page, so that statement rests on a CBIC circular's discussion and two secondary summaries[3][9]. The relief for smaller taxpayers is primary-sourced. Notification 07/2023-Central Tax, dated 31 March 2023, waives the late fee above the amounts below for returns under section 44 "for the financial year 2022-23 onwards"[10].
| Aggregate turnover | Per day (CGST) | Cap (CGST) | Total with SGST |
|---|
| Up to ₹5 crore | ₹25 | 0.02% of turnover in the State/UT | ₹50 a day; cap 0.04% |
| Above ₹5 crore, up to ₹20 crore | ₹50 | 0.02% of turnover in the State/UT | ₹100 a day; cap 0.04% |
| Above ₹20 crore | ₹100 (no waiver) | 0.25% of turnover in the State/UT | ₹200 a day; cap 0.50% |
The notification has only two rows, and the top row says "Twenty-five rupees per day, subject to a maximum of an amount calculated at 0.02 per cent. of turnover"[10]. The third row is what is left when no waiver applies, so it is the section 47(2) default, and the 0.50% combined cap follows from the 0.25% CGST cap doubled for SGST. The late fee is paid from the electronic cash ledger and cannot be set off against ITC[5]. Use the GST late fee and interest calculator for the exact day count.
An example: a trader with ₹12 crore turnover in one State files the complete return 25 days late. The rate is ₹50 + ₹50 = ₹100 a day, so 25 × ₹100 = ₹2,500. The cap is 0.02% × ₹12,00,00,000 = ₹24,000 per Act, ₹48,000 together. The cap is far away, so the fee is ₹2,500. The notification has no waiver for default beyond ₹20 crore, so a ₹30 crore business filing 25 days late pays 25 × ₹200 = ₹5,000.
Interest and DRC-03 on additional liability
If reconciliation shows you under-reported outward tax, pay the shortfall before filing GSTR-9. The route is Form GST DRC-03 from the cash ledger, with interest, and then you report the payment in Table 9; Table 14 is for differential tax on next-year adjustments, though secondary guides vary on this[5]. Interest on short-paid tax runs under section 50(1) at 18% a year from the day after the original due date to the payment date. The rates come from Notification 13/2017-Central Tax (28 June 2017): 18% under section 50(1) and 24% under section 50(3), confirmed via ICAI and Taxmann reproductions because the CBIC PDF was unavailable[12]. ITC wrongly availed and utilised draws the higher 24%, so reverse those first.
Missed ITC is a different story. One secondary guide says missed ITC generally cannot be claimed after you file GSTR-9, and that demand notices for FY 2024-25 onward are issued under section 74A[5]. Neither point is primary-sourced here.
The reconciliation workflow: books, GSTR-1, GSTR-3B, GSTR-2B
Run the four-way match in this order, because each step feeds the next.
Books vs GSTR-1. Compare monthly taxable value by rate. Differences are usually March invoices left out, or credit notes booked in a different month.
GSTR-1 vs GSTR-3B. Compare Table 3.1(a) to GSTR-1 totals. The gap is the cleanest evidence of under-reported tax.
Purchase register vs GSTR-2B. This sets Tables 6 and 8. The GST ITC Rescue Workbook for FY 2025-26 has a 2B-versus-books matcher with section 16(4) flags if you do not already have one; a spreadsheet pivot works as well.
ITC availed vs ITC due. Strip blocked credits under section 17(5), reverse Rule 37 and 37A items, then compare to GSTR-3B Table 4.
Tax paid vs tax payable. Compare Table 9 to the ledger and note any liability paid late.
Worked example: a ₹1.3 lakh mismatch
An illustrative Ahmedabad trader has ₹8.4 crore of FY 2025-26 turnover, so it files GSTR-9 and GSTR-9C. The reconciliation on 16 October gives these taxable-value totals:
| Source | Taxable outward value (₹) |
|---|
| Books (sales ledger) | 8,42,60,000 |
| GSTR-1 (all months) | 8,38,10,000 |
| GSTR-3B Table 3.1(a) | 8,35,40,000 |
The math:
Books minus GSTR-1: 8,42,60,000 − 8,38,10,000 = ₹4,50,000. These are March 2026 invoices never uploaded to GSTR-1.
GSTR-1 minus GSTR-3B: 8,38,10,000 − 8,35,40,000 = ₹2,70,000. These were reported in GSTR-1 but left out of the 3B.
Total unreported value: ₹4,50,000 + ₹2,70,000 = ₹7,20,000.
Tax at 18%: ₹7,20,000 × 0.18 = ₹1,29,600, i.e. ₹64,800 CGST and ₹64,800 SGST.
Interest at 18% a year from 21 April 2026, the day after the 20 April due date, to 20 December 2026, 244 days: 1,29,600 × 0.18 × 244 ÷ 365 = ₹15,594.
The example treats every difference as belonging to the March 2026 period, so a single interest start date applies.
Cash needed through DRC-03: ₹1,29,600 + ₹15,594 = ₹1,45,194.
On the credit side, GSTR-2B shows ITC of ₹21,40,000 against ₹22,10,000 in the purchase register, a gap of ₹70,000. Of that, ₹52,000 is one vendor who never filed GSTR-1, so the invoices are missing from GSTR-2B, and ₹18,000 is catering that section 17(5) blocks. Neither can be fixed in Table 8 by editing a number; the vendor has to file, or the claim stays out of the return. The ₹52,000 is the item with a clock on it, since credit not claimed by 30 November is gone. Pay the ₹1,45,194 first, report it, and only then file. Found now, the exposure is ₹1,45,194. Found in a notice instead, the same tax would carry section 74A interest and penalty on top.
How the 30 November ITC cut-off interacts with GSTR-9
Section 16(4) bars credit after the earlier of 30 November following the financial year or the date you file the annual return. Filing GSTR-9 on 5 November 2026 makes 5 November your cut-off. The full mechanics, Rule 37 and Rule 37A reversals and the October 3B due 20 November are in the sibling ITC deadline guide. Sequence matters: file GSTR-9 only after the October 2026 GSTR-3B, which is the last monthly return that can carry FY 2025-26 credit.
Mistakes CAs see every December
Filing early to be done. A GSTR-9 filed on 10 November resets the ITC cut-off to 10 November.
Accepting the pre-fill. Tables 4 and 6 fill from filed returns, so errors in those returns carry straight in.
Forgetting GSTR-9C is a second filing. Late fee runs until both are in[3].
Filing with pending returns. One report says the portal is blocking annual return filing by asking for pending GSTR-1 and 3B that are already filed, with no GSTN fix confirmed[4].
Dated calendar: 16 October to 31 December 2026
| Date | Action |
|---|
| Fri 16 to Sun 18 Oct | Pull books, GSTR-1, GSTR-3B and the twelve GSTR-2B statements; run the four-way match |
| Tue 20 Oct | September GSTR-3B for monthly filers; correct any current-year miss in this return |
| Thu 22 or Sat 24 Oct | QRMP quarterly GSTR-3B (state-based date) |
| Sun 1 to Sat 7 Nov | Clear IMS on FY 2025-26 invoices; chase vendors |
| Wed 11 Nov | Vendors' October GSTR-1 due; last clean date for late invoices to appear |
| Sat 14 Nov | October GSTR-2B generates; re-run the match |
| Fri 20 Nov | October GSTR-3B; claim, reverse and pay |
| Mon 30 Nov | Section 16(4) cut-off and last day to claim FY 2025-26 credit if GSTR-9 is not yet filed |
| Tue 1 to Fri 11 Dec | Pay any shortfall by DRC-03; freeze the numbers; prepare GSTR-9 drafts |
| Thu 31 Dec | Due date for GSTR-9 and GSTR-9C. File both well before the day |
Load these into the GST compliance calendar for 2026 so reminders reach the whole team. Verify every date on the GST portal, since extensions are common.
Frequently Asked Questions
Is GSTR-9 mandatory for FY 2025-26?
Yes, if aggregate turnover exceeds ₹2 crore. Notification 15/2025-Central Tax exempts those up to ₹2 crore for FY 2024-25 onwards.
When is GSTR-9C required?
When aggregate turnover for the year exceeds ₹5 crore, under Rule 80(3). It is self-certified, and the annual return is complete only when both GSTR-9 and GSTR-9C are filed.
What is the late fee for GSTR-9?
Under Notification 07/2023-CT it is ₹50 a day in total (₹25 CGST plus ₹25 SGST) up to ₹5 crore, ₹100 a day for ₹5 to ₹20 crore, each capped at 0.04% of turnover; above ₹20 crore the section 47(2) default of ₹200 a day applies.
Can I revise GSTR-9 after filing?
No. There is no revision facility. Short-paid tax is paid afterwards through DRC-03 with interest, so reconcile before you file.
Does filing GSTR-9 early affect my ITC?
Yes. Under section 16(4) the credit cut-off is the earlier of 30 November 2026 or your GSTR-9 filing date, so an early filing shortens your own window.
Do I report FY 2025-26 invoices filed after March 2026?
Yes. Supplies and notes reported in April to November 2026 returns that belong to FY 2025-26 go in Tables 10 and 11, and any differential tax in Table 14.
Sources
Notification 30/2021-Central Tax, substituting Rule 80 (found by search; text not fully read)
CBIC, Circular 246/03/2025-GST on late fee for delay in GSTR-9C
Tax Garden, GSTR-9 annual return filing guide for FY 2025-26 (secondary)
StudyCafe, GSTR-9/9C FY 2024-25 key updates, 25 October 2025 (secondary)
StudyCafe, GSTR-9 and 9C mandatory vs optional tables for FY 2024-25 (secondary)
Notification 13/2017-Central Tax, 28 June 2017, interest rates under section 50 (number and date cited; text confirmed via ICAI and Taxmann reproductions)
TaxGuru, Consequences of not filing GST annual return (secondary)
Notification 07/2023-Central Tax, 31 March 2023 (read in full)
Disclaimer: This article is for informational purposes only and does not constitute financial, tax, or legal advice. Consult a qualified professional for advice specific to your situation.
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