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Membership No. 250054 · DISA (ICAI)
Published
Short answer: GSTR-9 is due 31 December 2026 for FY 2025-26. It is required where aggregate turnover exceeds ₹2 crore, and GSTR-9C is added above ₹5 crore — self-certified, not audited. It cannot be revised, which is why the reconciliation belongs before the filing and not after.
The annual return is not another monthly return. It is a consolidation of what you already declared, and the work that decides whether it goes smoothly happens before the form is opened.
Filing is exempt where aggregate turnover for the year is ₹2 crore or less — Notification No. 15/2025-Central Tax, continuing an exemption CBIC has notified every year since GST began.
Two tests operate at once, and confusing them is the most common applicability error:
So a business registered in three states with ₹80 lakh of turnover in each is at ₹2.4 crore aggregate. It is above the threshold, and it files three returns.
Six categories sit outside Section 44 regardless of turnover:
| Registered as | Position |
|---|---|
| Composition taxpayer | Files GSTR-9A instead |
| Casual taxable person | Not required |
| Input Service Distributor | Not required |
| Non-resident taxable person | Not required |
| TDS deductor under Section 51 | Not required |
| TCS collector under Section 52 | Not required |
Above ₹5 crore aggregate turnover, GSTR-9C is filed alongside — the statement reconciling the declared figures to the audited accounts.
It is self-certified. The Finance Act 2021 amended Section 44 to remove both the GST audit and the CA/CMA certification, with effect from FY 2020-21. A large amount of published guidance — including material written this year — still describes GSTR-9C as a certified audit. It has not been one for several years. A chartered accountant may prepare it, and usually should, but the certification on the form is the taxpayer's own.
The commercial distinction is worth holding on to: GSTR-9 summarises what you filed; GSTR-9C is where it meets the books. The second is where the differences become visible, and it is the one that takes the time.
This is the substantive change for FY 2025-26, and it catches people who have filed the annual return for years without difficulty.
Table 8A — ITC available as per GSTR-2B — is now auto-populated through the Invoice Management System, rather than flowing directly from raw 2B data. IMS lets the recipient accept, reject or hold each invoice, and only accepted invoices flow through 2B into Table 8A.
The consequence: an invoice rejected in IMS does not appear in Table 8A, even where the credit is perfectly legitimate. If it was rejected in error, or rejected pending a dispute later settled with the supplier, the credit has to be reconciled manually and disclosed in the appropriate table rather than left to the auto-population.
That makes the IMS action log for the year a reconciliation input it never used to be. If nobody has been reviewing IMS actions month to month, that review is now part of the annual return exercise.
This is the actual work, and doing it in October rather than late December is the difference between a two-day filing and a two-week one.
This is a working reference, not the statute. Thresholds, the due date and the late-fee slab are all notification-driven and have been revised before — confirm the current position against the governing notification before filing.
Every registered person whose aggregate turnover for the year exceeds ₹2 crore. Below that, filing is exempt — Notification No. 15/2025-Central Tax continues the exemption CBIC has notified every year since FY 2017-18. Note the two different tests: the ₹2 crore threshold is measured on aggregate turnover across the PAN, but the return itself is filed separately for each GSTIN. A business registered in three states with ₹80 lakh in each is above the threshold, not below it.
Six categories are outside Section 44 entirely: a composition taxpayer, who files GSTR-9A instead; a casual taxable person; an Input Service Distributor; a non-resident taxable person; a person deducting TDS under Section 51; and a person collecting TCS under Section 52. Being outside it is a function of what you are registered as, not of turnover.
GSTR-9C is required where aggregate turnover exceeds ₹5 crore. It is self-certified — the Finance Act 2021 amended Section 44 to remove the audit and the CA/CMA certification, effective from FY 2020-21. A great deal of published material still describes it as a certified GST audit; that has not been the position for several years. A CA may of course prepare it, but the certification is yours.
31 December 2026 for FY 2025-26, under Section 44. Extensions have been notified in some past years, but they are announced late and are never a basis for planning.
It is a slab, not a flat figure, from FY 2022-23 onwards under Notification No. 07/2023-Central Tax. Aggregate turnover up to ₹5 crore: ₹50 per day (₹25 CGST plus ₹25 SGST), capped at 0.04% of turnover in the State or Union Territory. Above ₹5 crore and up to ₹20 crore: ₹100 per day, same 0.04% cap. Above ₹20 crore: the general Section 47(2) position of ₹200 per day, capped at 0.25% of State turnover under each Act. Interest under Section 50 runs separately on any tax that turns out to be short.
No. There is no revision facility, which is the entire reason the reconciliation is done before the form is opened rather than after. An error discovered afterwards has to be dealt with through the following year's return or, if it is a tax shortfall, by paying it in DRC-03 — neither of which is as clean as getting it right the first time.
Beyond the late fee, Section 44(2) bars the return from being filed at all once three years have passed from the due date. The year then closes permanently unreconciled, which is a poor position to be in if that year is later picked up for scrutiny. The same three-year bar applies across the return forms.
GSTR-9 is built from what was actually declared in the returns for the year — it is a consolidation, not a fresh computation, and it should not be used to restate turnover. The differences are explained rather than overwritten: GSTR-9C is where the declared figure is reconciled to the audited accounts, with the reasons for each difference set out. Where the difference is a genuine short-declaration, the tax is paid in DRC-03; where it is timing, credit notes, or supplies recorded net, it is explained.
Send the GSTR-1 and 3B summaries for the year and the trial balance. Where the difference actually sits, and whether it is a reconciliation item or an exposure, is established before anything is filed — and the return cannot be revised once it goes.
Related service: GST Registration & Returns