Short answer: for FY 2025-26, Table 8A of GSTR-9 is the sum of twelve months of your IMS actions, not a neutral download of what suppliers reported. Anything you rejected, or left pending, is not in it. The annual return only reports credit; it cannot claim it. The last GSTR-3B that can carry a FY 2025-26 invoice is October 2026's, due 20 November. So the reconciliation that decides your credit position belongs in October, and the annual return due 31 December merely records the result.
Who has to file, the thresholds and the late fee are in GSTR-9 and 9C for FY 2025-26: who files, and by when. This note is about the one table that changed character.
The Invoice Management System went live from the October 2024 tax period. From then, every document a supplier reports in GSTR-1, GSTR-1A or the IFF lands on your IMS dashboard, and GSTR-2B is generated from what you did with it:
| Your action in IMS | Effect on that month's GSTR-2B |
|---|
| Accept | Included; credit auto-populates into GSTR-3B |
| No action | Deemed accepted when 2B is generated; included |
| Reject | Excluded |
| Pending | Excluded until accepted, in whichever later month that happens |
FY 2024-25 was a hybrid: six months of the old auto-drafted 2B and six months of IMS. FY 2025-26 is the first year where all twelve 2Bs are IMS-shaped. Since the annual return's Table 8A is populated from GSTR-2B, it is now a record of your own accept, reject and pending decisions, taken month by month, by whoever was operating the dashboard.
Where nobody was operating it, the position is simple: everything was deemed accepted, 8A is complete, and the risk sits on the other side, in credit you took on invoices that should have been rejected. Where somebody was operating it, the risk is the reverse: legitimate credit rejected in haste or parked as pending and forgotten.
Table 8 is the reconciliation of credit available against credit taken. Its rows:
| Row | What it holds | Source |
|---|
| 8A | ITC as per GSTR-2B for the year | Auto-populated; IMS-shaped |
| 8B | ITC as per Table 6B and 6H (credit taken in GSTR-3B during the year, on inward supplies) | From Table 6 |
| 8C | ITC on FY 2025-26 invoices taken in GSTR-3B after 31 March 2026, up to the cut-off | Your working |
| 8D | 8A minus 8B minus 8C: available but not taken | Computed |
| 8E / 8F | 8D split into ITC available but not availed, and ineligible | Your classification |
Two things follow from the source of 8A.
8D understates a rejection error. 8D is the difference between what 2B offered and what you took. An invoice wrongly rejected in IMS was never in 2B, so it is not in 8A, so it is not in 8D. The auto-populated figures will look reconciled while a credit is missing. The only place it shows is the comparison of 8A against the purchase register, which is the reconciliation most people skip because the form does not ask for it.
8C is where October's work lands. Every FY 2025-26 invoice whose credit you take in the April to October 2026 returns goes in 8C. If the reconciliation finds credit that can still be recovered, this is the row it will end up in, and the GSTR-3B that carries it has to be filed by 20 November 2026.
Table 6, where credit taken is broken down by category, has its own change carried over from last year: Table 6A1, introduced by Notification 13/2025-Central Tax, separates credit of the previous financial year availed in the current year, so that 6A no longer mixes two years' credit. Credit on FY 2024-25 invoices taken in April to October 2025 goes there, not in 6B.
Section 16(4) allows credit on an invoice or debit note only up to 30 November following the end of the financial year, or the date of filing the annual return, whichever is earlier. Operationally, that is the GSTR-3B for October 2026, due 20 November 2026.
GSTR-9 does not claim credit. It reports credit already claimed in GSTR-3B and reconciles it. A credit discovered while preparing the annual return in December is a credit discovered after the last return that could have carried it. It can be shown in 8E as "available but not availed" and it is lost.
Which is why the sequence is:
- October: reconcile IMS, 2B and the purchase register; get suppliers to re-report anything wrongly rejected; accept anything still pending; claim the balance in the October GSTR-3B.
- 20 November: last GSTR-3B that can carry FY 2025-26 credit.
- December: prepare and file GSTR-9 on numbers that are already final.
1. Pull the IMS action log for all twelve months, not just the 2B PDFs. The dashboard shows what was rejected and what is still pending. Export it before it scrolls out of the default view.
2. Purchase register against 8A. Every supplier invoice in the books that is not in 8A is one of four things: not reported by the supplier, reported to the wrong GSTIN, rejected by you, or pending. The first two need the supplier; the last two need you. The conditions that decide whether the credit is claimable at all, including the supplier having paid the tax, are in why GSTR-2B decides what you can claim.
3. Rejections. For each rejected record, decide whether the rejection was right. Where it was not, ask the supplier to report the document again in GSTR-1A or the next GSTR-1 so that it flows into a later 2B, and accept it there. This has to complete in time for the October return.
4. Pending. Accept or reject every pending FY 2025-26 record. From the October 2025 period, credit notes and certain other documents can also be kept pending, so sweep those too; a pending credit note left unactioned distorts the reversal side.
5. 8B against the GSTR-3B trail. Credit taken in 3B during the year against 6B and 6H. Differences are usually reversals under Rule 42/43 booked in one table and not the other, or credit on reverse charge sitting in 6C/6D.
6. 8C. Total the FY 2025-26 credit taken in the April to October 2026 returns. This is the number the cut-off protects.
7. Rate split in the HSN tables. GST 2.0 moved most goods and services to 5% or 18% from 22 September 2025. Tables 17 and 18 are rate-wise, so each HSN supplied across that date appears twice, and the two lines must tie to what GSTR-1 reported for the pre- and post-change periods. GSTR-9C carries the same split in its rate-wise reconciliation.
8. Pay any shortfall in DRC-03 before filing. Additional liability found in the reconciliation is paid through DRC-03 and disclosed in Table 14; it is not paid through the annual return itself.
- Treating 8A as the truth. It is a record of decisions, and this year the decisions were yours.
- Reconciling in December. By then the only return that could carry a missing credit has been filed.
- Letting the consultant's dashboard be the only copy. The IMS log is evidence in any later dispute over reversals or mismatches; keep an export.
- Ignoring 8D because it is small. A small 8D with a large gap to the purchase register means credit is missing from 8A, not that the year is clean.
- Forgetting that the return cannot be revised. What is filed in December is final. Ties to the three-year bar as well: an unfiled annual return for an older year does not become safe with time.
A mismatch that survives into the annual return is the same mismatch that produces a DRC-01C intimation, and the ladder from there is set out in GST notices: from ASMT-10 to a demand.
Table structures and the Section 16(4) cut-off are notification-driven, and the ₹2 crore exemption rests on Notification 15/2025-Central Tax. Confirm the governing notifications and any extension of the 31 December 2026 date before filing.