GSTR-9 Annual Return for FY 2025-26: The Complete Guide to Concepts, Registers & ITC Rules

Every December, thousands of businesses rush to file GSTR-9, the annual return under GST, only to discover that the real work was never the form. The real work is the data behind it: sales registers, export documents, ITC reversals, RCM payments, advances and stock. When the books, GSTR-1 and GSTR-3B do not agree, GSTR-9 turns into a mismatch report that invites scrutiny.

This guide is the written companion to Part 1 of my GSTR-9 Masterclass for FY 2025-26. It walks you through the law (Sec. 44 and Rule 80), who must file, the seven registers that feed the return, every ITC reversal rule you must apply before filing, special cases such as NIL returns, late fees, the changes that affect FY 2025-26, the key dates and a ten-point pre-filing checklist. Part 2 covers the actual form, table by table. For the changes recommended after the year closed, see the 57th GST Council meeting update.

WhatsApp Channel for notes and updates on GST, Income Tax, TDS, TCS, Export and Accountancy: whatsapp.com/channel/0029Va6GOVE9MF92Ylmo7e0L

What This Guide Covers

The guide follows the same five modules as the video, so you can read and watch side by side.

1. Annual Return Basics: Sec. 44, who files, records under Sec. 35 and Rule 56, and the golden rule Books = GSTR-1 = GSTR-3B
2. Sales-Side Registers: outward supplies, place and time of supply, exports of goods and services, Rule 96A, imports
3. ITC Eligibility & Reversals: Sec. 16(2), temporary vs permanent reversal, Rules 37, 37A, 38, 39, 42 and 43, Sec. 17(5) and Sec. 18
4. Other Registers: RCM, stock and advances
5. Special Cases & Readiness: NIL GSTR-9, late fee, other consequences, what is new in FY 2025-26, key dates and the pre-filing checklist

Module 1: Annual Return Basics

1. GSTR-9 at a Glance: Sec. 44 and Rule 80

GSTR-9 is the annual return that every regular taxpayer (unless exempt) files under Sec. 44 of the CGST Act read with Rule 80. It brings together, for one financial year, everything you declared month after month in GSTR-1 and GSTR-3B, and lines it up with your books of account.

Six points define how the return works:

• Pre-condition: all GSTR-1 and GSTR-3B returns for FY 2025-26 must be filed before the portal allows GSTR-9.
• Last chance to correct: GSTR-9 is where you disclose errors and omissions of the year. Any tax short paid is paid through Form DRC-03.
• Consolidation: it is one summary of GSTR-1, GSTR-3B and your books.
• No revision: once filed, GSTR-9 cannot be revised, so it must be right the first time.
• Three-year bar under Sec. 44(2): the return for FY 2025-26 cannot be filed after 31.12.2029.
• GSTR-9C: where aggregate turnover exceeds ₹5 crore, a self-certified reconciliation statement is filed after GSTR-9.

Composition taxpayers file GSTR-9A instead. If you opted into or out of composition during the year, you file both GSTR-9 and GSTR-9A for the respective periods.

2. Who Must File GSTR-9, and Who Is Exempt

Applicability is a two-step test. First, check whether you fall in a category that Sec. 44(1) excludes altogether. Second, check your aggregate turnover.

Step 1: Excluded categories under Sec. 44(1)

The following do not file GSTR-9 at all: an Input Service Distributor, a person deducting TDS under Sec. 51, a person collecting TCS (e-commerce operator) under Sec. 52, a casual taxable person, a non-resident taxable person, and a Government department audited by the CAG.

Step 2: The ₹2 crore turnover test

Under Notification No. 15/2025-Central Tax dated 17.09.2025, registered persons whose aggregate turnover is up to ₹2 crore are exempt from filing the annual return from FY 2024-25 onwards. This exemption therefore applies to FY 2025-26 as well. Above ₹2 crore, GSTR-9 is mandatory; above ₹5 crore, GSTR-9C is also required.

3. Source No. 1: Accounts and Records under Sec. 35 and Rule 56

GSTR-9 is only as good as the records behind it. Sec. 35(1) requires every registered person to keep, at the principal place of business, true and correct accounts of production or manufacture, inward and outward supplies, stock of goods, ITC availed, and output tax payable and paid.

Rule 56 adds more detail. You must also maintain records of imports, exports and supplies under reverse charge with their documents; a stock account showing opening balance, receipts, supplies, goods lost, gifts and closing balance; advances received, paid and adjusted; registers of invoices, credit notes, debit notes and delivery challans; names and addresses of suppliers and customers; and details of storage premises, including goods in transit.

• Multiple places of business: accounts must be kept at each place of business.
• Goods not accounted for, or found at an undeclared place: under Sec. 35(6), the officer can determine tax as if those goods had been supplied.
• Demand: proceedings arise under Sec. 73 or 74 up to FY 2023-24, and under Sec. 74A from FY 2024-25 onwards. FY 2025-26 therefore falls under Sec. 74A.

4. The Golden Rule: Books = GSTR-1 = GSTR-3B

Before you fill a single table, three data sets must agree: your books of account, your GSTR-1 / GSTR-1A / IFF (outward supply details) and your GSTR-3B (summary return and tax payment). When all three match, GSTR-9 becomes a clean summary. When they do not, you face one of two cases.

Case	What happened	What to do
Case I	Tax short paid during the year	Declare in GSTR-9 and pay the tax with interest through DRC-03
Case II	Tax paid in excess	Declare in GSTR-9; claim refund through RFD-01, if eligible

Module 2: Sales-Side Registers

Outward supply data drives Part II and Part IV of the return. This module covers the registers that capture it.

5. Register #1: The Outward Register

Every sales entry must capture three things, so that it lands in the right table of GSTR-9:

• The document issued: tax invoice, bill of supply, debit note or credit note.
• The type of supply: B2B or B2C; export with or without IGST; SEZ supply with or without IGST; deemed exports; supplies on which the buyer pays tax under RCM; and deemed supplies under Schedule I.
• Tags on each entry: place of supply, HSN and rate, time of supply, and whether it is a composite or mixed supply.

6. Place of Supply, and Composite vs Mixed Supply

Place of supply decides whether a transaction attracts IGST or CGST + SGST. Reporting it wrongly means tax was paid under the wrong head, which GSTR-9 cannot fix by itself.

Place of supply under the IGST Act

• Goods (Sec. 10): where movement is involved, the place where movement ends for delivery; where there is no movement, the location of the goods at the time of delivery.
• Services (Sec. 12): to a registered recipient, the location of the recipient; to an unregistered recipient, the address on record, failing which the location of the supplier.
• Sec. 12 applies when both supplier and recipient are in India; Sec. 13 applies when either of them is outside India.

Composite vs mixed supply: Sec. 8

Basis	Composite supply	Mixed supply
Bundling	Naturally bundled	Not naturally bundled
Sold separately?	Normally no	Yes, can be
Tax rate	Rate of the principal supply	Highest rate in the bundle
Example	Goods with packing, transport and insurance	Gift hamper of sweets, dry fruits and toys

7. Time of Supply: Goods (Sec. 12) vs Services (Sec. 13)

Time of supply decides the tax period, and therefore whether a transaction belongs to FY 2025-26 or FY 2026-27. This matters most for transactions near 31 March 2026.

Situation	Goods: Sec. 12	Services: Sec. 13
Invoice issued within time (Sec. 31)	Date of invoice	Earlier of invoice date or payment date
Invoice not issued in time	Last date by which the invoice should have been issued	Earlier of date of provision or payment date
Neither of the above	Not applicable (advance for goods is not taxable: N/N 66/2017)	Date the recipient records the service in its books
Reverse charge	Earliest of receipt of goods, payment, or the day after 30 days from invoice	Earlier of payment, or the day after 60 days from invoice

The time-of-supply rules for vouchers, sub-section (4) of Sec. 12 and Sec. 13, were omitted with effect from 01.10.2025 by the Finance Act, 2025.

8. Register #2: Export of Goods under Sec. 2(5) of the IGST Act

An export of goods means taking goods out of India to a place outside India. A foreign buyer or a foreign-currency invoice does not, on its own, make a transaction an export.

Example: a buyer in the USA places an order with a Delhi exporter for 500 kg of Basmati rice. The exporter raises an invoice in US dollars and receives payment in foreign exchange. But the rice is delivered in Punjabi Bagh, Delhi. Since the goods never left India, the place of supply is in India and this is a domestic taxable supply. It cannot be reported as an export in Table 6A of GSTR-1.

The proof of an export of goods is the shipping bill together with the EGM or bill of lading, not the currency of the invoice.

9. Rule 96A: Export under LUT or Bond without IGST

When you export without paying IGST under a bond or Letter of Undertaking (Form RFD-11), you make a binding promise: if the conditions are not met, you will pay IGST with interest under Sec. 50(1). The LUT is valid for the whole financial year and must be filed before you export.

• Goods not exported: if goods are not exported within 3 months of the invoice, IGST with interest must be paid within 15 days after that period.
• Services, payment not received: if payment is not received within 1 year or the FEMA period (whichever is later, or as extended by the Commissioner), tax with interest must be paid within 15 days after that period.
• Data flow: export details in GSTR-1/1A (Table 6A) flow to ICEGATE and are matched with the shipping bill.
• Rule 96B: if export proceeds are not realised within the FEMA period, the refund already granted is recovered.
• RBI relief (November 2025): the period for realising export proceeds was extended from 9 months to 15 months. Recheck any Rule 96A or 96B cases in your FY 2025-26 data against this.

10. Export of Services: The Five Conditions of Sec. 2(6) of the IGST Act

A supply of services is an export only if all five conditions are met:

1. The supplier is located in India.
2. The recipient is located outside India.
3. The place of supply is outside India.
4. Payment is received in convertible foreign exchange (or in Indian rupees where permitted by the RBI).
5. The supplier and recipient are not merely establishments of a distinct person.

Example: a consulting firm in India gives advice to a client in Canada. The place of supply is outside India and US$ 50,000 is received in the firm’s bank account. All five conditions are met, so this is a zero-rated export of service. If even one condition fails, it becomes a taxable supply.

Evidence: keep FIRC or e-BRC records matched invoice by invoice against your export register.

11. Register #3: The Import Register, Goods vs Services

Import of goods	Import of services
IGST is levied at customs under Sec. 3(7) of the Customs Tariff Act, on a value that includes basic customs duty	It is a supply even if not in the course of business, if for consideration (Sec. 7(1)(b) of the CGST Act)
Document: Bill of Entry, which must carry your GSTIN (update it on ICEGATE)	It is always an inter-State supply (Sec. 7(4) of the IGST Act)
ITC is available only on IGST; basic customs duty and social welfare surcharge are not creditable	Tax is paid by the recipient under reverse charge, in cash
Goods brought from an SEZ into the DTA are also covered	Issue a self-invoice and payment voucher; convert at the exchange rate under Rule 34(2)

Import of services from a related person without consideration, in the course of business, is also a supply under Schedule I.

Module 3: ITC Eligibility and Reversals

This is the module where most GSTR-9 errors arise. GSTR-9 reports ITC availed, reversed and lapsed, so every reversal rule must be applied in GSTR-3B (or through DRC-03) before you file.

12. Register #4: Sec. 16(2), the Six Conditions for ITC

1. You possess the document: a tax invoice or debit note.
2. It is reflected in GSTR-2B: the supplier has filed GSTR-1 or IFF, and you have not rejected it in IMS.
3. You have received the goods or services: a GRN for goods and a books entry for services.
4. The supplier has paid the tax: if not, reverse under Rule 37A.
5. You have filed your GSTR-3B: the return under Sec. 39 has been furnished.
6. You have paid the supplier within 180 days: if not, reverse under Rule 37.

After these six conditions, the credit must pass two more gates:

• Gate 1: not blocked. No ITC is available on items listed in Sec. 17(5).
• Gate 2: in time under Sec. 16(4). ITC for FY 2025-26 can be taken up to 30.11.2026 or the date of filing GSTR-9, whichever is earlier.

13. Temporary vs Permanent Reversal of ITC

Once ITC appearing in GSTR-2B is availed in GSTR-3B Table 4A(5), any reversal falls into one of two buckets, as explained in Circular 170/02/2022-GST:

Temporary reversal: Table 4B(2)	Permanent reversal: Table 4B(1)
Goods or services not yet received	Blocked credits under Sec. 17(5)
Invoice not yet recorded in books	Reversals under Rules 38, 42 and 43
Supplier not paid within 180 days (Rule 37)	Goods lost, stolen, destroyed or given as free samples
Supplier’s GSTR-3B not filed (Rule 37A)	Personal or non-business use
Can be reclaimed in Table 4A(5) and disclosed in Table 4D(1)	Never reclaimed

14. Rule 37: Pay Your Supplier within 180 Days

Under the second proviso to Sec. 16(2) read with Rule 37, if you do not pay a supplier the value plus tax within 180 days of the invoice date, you must reverse the ITC on the unpaid portion, with interest under Sec. 50. Once you pay, you can re-avail the credit, and there is no time limit for re-availing.

Rule 37 does not apply to supplies under reverse charge, deemed supplies without consideration under Schedule I, and amounts added to value under Sec. 15(2)(b).

15. Rule 37A: When Your Supplier Does Not Pay the Tax

Sometimes the supplier files GSTR-1, so the credit appears in your GSTR-2B and you avail it, but the supplier never files GSTR-3B and never pays the tax. Since Sec. 16(2)(c) makes ITC depend on tax actually paid by the supplier, Rule 37A requires you to reverse that credit.

• Supplier cut-off: if the supplier has not filed GSTR-3B for the relevant period by 30.09.2026,
• your reversal: you must reverse the ITC by 30.11.2026, failing which it is payable with interest.
• Re-availment: once the supplier files the GSTR-3B, you can re-avail the credit.

Practice tip: track each supplier’s GSTR-3B filing status on the portal before September 2026 and keep a vendor follow-up sheet.

16. Rule 38: The 50% Option for Banks, FIs and NBFCs

Normally, Sec. 17(2) requires proportionate reversal of common credit through Rules 42 and 43. Banks, financial institutions and NBFCs can instead opt under Sec. 17(4) to take a flat 50% of eligible ITC every month.

• Computation: total ITC for the month, less ITC for non-business use, less blocked credits under Sec. 17(5), gives eligible ITC. 50% of that is allowed; the other 50% lapses.
• Lock-in: the option cannot be withdrawn during the financial year.
• Carve-out: the 50% restriction does not apply to supplies received from your own GSTINs on the same PAN.

17. Rule 39: The Input Service Distributor (ISD)

Where common input services are received at the head office for several branches, the head office, registered as an ISD, distributes that credit to the branches. From 01.04.2025, ISD registration is mandatory for distributing such common credit, and this includes input services on which tax is paid under reverse charge.

• Return: the ISD files GSTR-6 by the 13th of the following month.
• Same-State branch: CGST + SGST goes as CGST + SGST; IGST goes as IGST.
• Other-State branch: all credit is distributed as IGST.
• Formula: a branch’s share = (branch turnover ÷ total turnover of the recipient units) × credit, using turnover of the previous financial year, only among units to which the service relates.
• Credit is distributed in the same month; eligible and ineligible ITC are distributed separately; an ISD credit note reduces credit in the same ratio; and excess distribution is recovered with interest and penalty.

18. Rule 42: Common ITC on Inputs and Input Services

If you make both taxable and exempt supplies, or use inputs partly for non-business purposes, Rule 42 decides how much common credit you keep.

Start with T, the total ITC on inputs and input services. Subtract T1 (exclusively non-business), T2 (exclusively for exempt supplies) and T3 (blocked under Sec. 17(5)) to arrive at C1. Subtract T4 (exclusively for taxable supplies, including zero-rated) to arrive at C2, the common credit. Then:

• D1 = (E ÷ F) × C2 is reversed as the exempt share, where E is exempt turnover and F is total turnover for the period.
• D2 = 5% × C2 is reversed as the non-business share.
• C3 = C2 − D1 − D2 is the eligible common ITC.

The computation is done every month in GSTR-3B. At year-end, a true-up on actual annual figures is done by the due date of the September 2026 return: any excess reversal still required is paid with interest from 01.04.2026, and any excess reversed earlier can be reclaimed.

19. Rule 43: Common ITC on Capital Goods

For capital goods, the treatment depends on how the asset is used:

• Used only for non-business or exempt supplies: no ITC.
• Used only for taxable supplies: full ITC.
• Common use: the credit (Tc) is spread over a useful life of 5 years (60 months). Monthly credit Tm = Tc ÷ 60, and the exempt share Te = (E ÷ F) × Tm is reversed every month.

For real estate, a final reversal is computed on completion of the project. Delay in reversal attracts interest under Sec. 50.

20. Blocked Credits under Sec. 17(5)

Sec. 17(5) lists credits that are blocked even when all Sec. 16 conditions are met, along with the situations where they are still allowed.

ITC blocked on	ITC still allowed when
Motor vehicles (up to 13 seats), vessels and aircraft, and their insurance and repair	Used for further supply, passenger transport, training in driving, or transport of goods (vessels and aircraft)
Food and beverages, outdoor catering, beauty treatment, health services, cosmetic surgery, vehicle hire, life and health insurance	Used for the same line of outward supply or as part of a composite supply, or obligatory for the employer under any law
Club or fitness membership; travel benefits to employees (LTC)	Only if obligatory for the employer under any law
Works contract or construction of immovable property on own account	“Plant and machinery” (retrospective from 01.07.2017 by the Finance Act, 2025), or for further works contract supply
Tax paid under composition; inputs of a non-resident taxable person	For a non-resident taxable person, goods imported by him
Personal use; goods lost, stolen, destroyed, written off, given as gifts or free samples	Not allowed
CSR expenditure; tax paid under Sec. 74 (up to FY 2023-24), Sec. 129 and Sec. 130	Not allowed

21. Sec. 18: ITC in Special Cases

Sec. 18 allows credit on stock (and in some cases capital goods) when your status changes, and requires you to pay it back in the reverse situation.

Situation	ITC allowed on	Pay back / reverse
Newly liable to register, applies within 30 days: Sec. 18(1)(a)	Inputs in stock, semi-finished and finished goods held on the day before liability	—
Voluntary registration: Sec. 18(1)(b)	The same, held on the day before registration	—
Composition to regular: Sec. 18(1)(c)	Stock and capital goods (capital goods reduced by 5% per quarter)	—
Exempt supply becomes taxable: Sec. 18(1)(d)	Stock and capital goods used for the exempt supply	—
Regular to composition, or taxable to exempt: Sec. 18(4)	—	Pay the ITC on stock and capital goods (Form ITC-03)
Sale, merger, demerger or transfer: Sec. 18(3)	Unused ITC moves to the transferee (Form ITC-02)	—

Example: a person becomes liable to register on 01.11.2025 and applies on 13.11.2025, within 30 days. ITC is available on stock held on 31.10.2025. The claim is made in Form ITC-01 within 30 days, and no ITC is allowed on invoices older than one year (Sec. 18(2)).

Module 4: Other Registers

22. Register #5: The RCM Register

Inward supplies under reverse charge, whether under Sec. 9(3), Sec. 9(4) or as import of services, need their own register because the tax flows in a different way.

• Registered supplier: the supplier issues a tax invoice marked for reverse charge.
• Unregistered supplier: you issue a self-invoice within 30 days of receipt (Rule 47A).
• Issue a payment voucher when you pay (Sec. 31(3)(g)).
• Pay the tax in cash (GSTR-3B Table 3.1(d)), and only then take the ITC.
• Place of supply: Sec. 10 for goods (other than imported or exported goods), Sec. 12 for services where both parties are in India, and Sec. 13 where either party is outside India.

23. Register #6: The Stock Register under Rule 56(2)

The stock register follows a simple equation: opening balance + receipts − supplies − goods lost, stolen, destroyed or written off − gifts and free samples = closing balance. It must be kept separately for raw material, finished goods, and scrap and wastage.

It matters for GSTR-9 because it exposes three things:

• Blocked credit under Sec. 17(5)(h): goods lost, stolen, destroyed, gifted or given as samples require ITC reversal.
• Job work under Sec. 143: inputs not returned within 1 year, or capital goods within 3 years, become a deemed supply.
• Sale on approval: goods not returned within 6 months become a supply, and an invoice must be raised.

Composition taxpayers are not required to keep stock accounts under Rule 56(2).

24. Register #7: The Advance Register, Goods vs Services

Goods: no GST on advance	Services: GST on advance
N/N 66/2017-CT dated 15.11.2017 applies to all taxpayers except composition taxpayers (earlier N/N 40/2017 covered only turnover up to ₹1.5 crore)	Tax is payable on receipt, since the time of supply under Sec. 13 is triggered
Exception: specified actionable claims (N/N 50/2023)	Issue a receipt voucher (Sec. 31(3)(d)); if no supply follows, issue a refund voucher (Sec. 31(3)(e))

Rule 56(3) requires a separate account of advances. Here is how the register works for FY 2025-26:

Advance register: FY 2025-26	₹
Opening balance (01.04.2025)	95,000
Add: advances received in FY 2025-26	56,000
Less: adjusted from opening balance against tax invoices	37,000
Less: adjusted from opening balance against refund vouchers	—
Less: adjusted from FY 2025-26 advances against tax invoices	49,000
Less: adjusted from FY 2025-26 advances against refund vouchers	6,000
Closing balance (31.03.2026)	59,000

The closing balance of ₹59,000 is made up of ₹58,000 of old advances (₹95,000 − ₹37,000, on which tax was paid in earlier years) and ₹1,000 of FY 2025-26 advances (₹56,000 − ₹49,000 − ₹6,000, on which tax was paid this year and the invoice is still pending). Separating the two tells you which advances belong in this year’s GSTR-9.

Module 5: Special Cases and Filing Readiness

25. NIL GSTR-9 and Cancelled Registrations

Example: a registered person with its principal place of business in Delhi has a PAN-India aggregate turnover above ₹2 crore. Its Maharashtra and Gujarat GSTINs are active, but the Haryana GSTIN had no transactions during the year. Because the test is at PAN level, the Haryana GSTIN must file a NIL GSTR-9.

A NIL GSTR-9 can be filed only if all of the following are nil: sales, purchases, any liability, ITC claimed, refund claimed or received, and any demand order.

Cancelled registration: if a GSTIN was cancelled during FY 2025-26, no GSTR-9 is needed only where the final return (GSTR-10) was filed and the cancellation was completed before 31.03.2026. Otherwise, GSTR-9 is required (where turnover exceeds ₹2 crore).

26. Late Fee for Delayed GSTR-9 under Sec. 47(2)

Aggregate turnover	Late fee per day	Maximum (each of CGST and SGST)
Up to ₹5 crore	₹25 CGST + ₹25 SGST = ₹50	0.02% of turnover in the State / UT
₹5 crore to ₹20 crore	₹50 CGST + ₹50 SGST = ₹100	0.02% of turnover in the State / UT
Above ₹20 crore	₹100 CGST + ₹100 SGST = ₹200	0.25% of turnover in the State / UT

These rates apply under Sec. 47(2) read with N/N 07/2023-CT dated 31.03.2023, from FY 2022-23 onwards. Delay in filing GSTR-9C also attracts late fee, as clarified in Circular 246/03/2025-GST.

27. Beyond the Late Fee: Other Consequences

• Sec. 46, notice to a defaulter: a GSTR-3A notice is issued, and the return must be filed within 15 days.
• Sec. 125, general penalty: up to ₹25,000 CGST + ₹25,000 SGST, imposed only after adjudication, not routinely.
• Sec. 44(2), three-year time bar: the FY 2025-26 GSTR-9 cannot be filed after 31.12.2029; the portal enforces this.
• Scrutiny and demand: mismatches lead to scrutiny under Sec. 61 and demand under Sec. 74A (FY 2024-25 onwards).

28. What Is New for FY 2025-26

Eight changes affect the data you report for FY 2025-26:

Effective	Change	Impact on GSTR-9 data
22.09.2025	GST 2.0 rates	5% / 18% / 40% slabs; compensation cess ends (except tobacco). Split sales and HSN by rate.
From July 2025	GSTR-3B hard-lock	Auto-filled liability cannot be edited; fix through GSTR-1A or IFF.
01.10.2025	Credit notes under Sec. 34(2)	Output tax falls only if the buyer reverses ITC.
01.10.2025	Vouchers	Time-of-supply rules for vouchers omitted.
01.04.2025	ISD mandatory	Common input services, including RCM services, routed through the ISD.
Retro 01.07.2017	Sec. 17(5)(d)	Reads “plant and machinery”; the Safari Retreats view is overridden.
13.11.2025	Export realisation	RBI extended the period from 9 to 15 months; recheck Rule 96A / 96B cases.
22.09.2025	GSTR-9 format revised	Prior-year ITC split, a Rule 38 row and next-year import ITC (covered in Part 2).

29. Key Dates for FY 2025-26

Date	What happens
01.04.2025	Financial year starts; ISD registration mandatory
22.09.2025	GST 2.0 rates come into force
01.10.2025	Sec. 34(2) credit-note rule applies
31.03.2026	Financial year closes; finalise the books
30.09.2026	Supplier GSTR-3B cut-off for Rule 37A
20.10.2026	September 2026 GSTR-3B due; Rule 42 / 43 annual true-up
30.11.2026	Last date for ITC, credit notes, corrections and Rule 37A reversal
31.12.2026	GSTR-9 and GSTR-9C due date
31.12.2029	Time bar: filing window closes

The critical cluster is 30.09.2026, 20.10.2026, 30.11.2026 and 31.12.2026. Most corrections must be completed by 30 November, a full month before GSTR-9 is due.

30. Pre-Filing Checklist for FY 2025-26

Run through these ten checks before you open the form:

1. All GSTR-1/1A and GSTR-3B returns for FY 2025-26 are filed.
2. Books, GSTR-1 and GSTR-3B are reconciled.
3. Sales are split by type of supply and by pre- and post-22.09.2025 rates.
4. Credit notes, debit notes and amendments up to 30.11.2026 are listed.
5. Exports: LUT, shipping bills, BRC/FIRC and Rule 96A defaults are verified.
6. GSTR-2B (IMS), the purchase register and GSTR-3B ITC are matched.
7. Reversals under Rules 37, 37A, 38, 42 and 43 and Sec. 17(5) are done.
8. RCM tax is paid in cash and self-invoices are issued.
9. Advance, stock and job-work (Sec. 143) registers are reviewed.
10. The HSN summary (4/6-digit) is ready, and any short tax is paid through DRC-03.

Coming Next: Part 2, Form GSTR-9 Table by Table

Part 2 is now published: GSTR-9 for FY 2025-26, the table-by-table filing and reconciliation guide.

With the data ready, Part 2 fills the actual form on the GST portal, table by table: basic details, outward and inward supplies, ITC availed, reversed and lapsed, tax paid, next-year transactions, and demands, refunds, HSN and late fee. It also covers the tax liability and ITC comparison reports and the points to check before you submit.

Frequently Asked Questions

What is the due date of GSTR-9 for FY 2025-26?

31 December 2026. GSTR-9C, where applicable, is due on the same date.

Is GSTR-9 mandatory if my turnover is below ₹2 crore?

No. Under N/N 15/2025-CT dated 17.09.2025, registered persons with aggregate turnover up to ₹2 crore are exempt from FY 2024-25 onwards. Remember that turnover is counted across all GSTINs on the same PAN.

Can I revise GSTR-9 after filing?

No. GSTR-9 cannot be revised once filed, so reconcile your books, GSTR-1 and GSTR-3B before filing.

Can I claim missed ITC through GSTR-9?

No. ITC cannot be availed or reversed through GSTR-9. ITC for FY 2025-26 must be claimed in GSTR-3B by 30.11.2026 (or the GSTR-9 filing date, if earlier), and reversals are made through GSTR-3B or DRC-03.

What if I paid less tax during the year?

Declare it in GSTR-9 and pay the short tax with interest through DRC-03.

Do I need to file GSTR-9 for a GSTIN with no transactions?

Yes, if your PAN-level aggregate turnover exceeds ₹2 crore. File a NIL return, provided every element (sales, purchases, liability, ITC, refund and demand) is nil.

What is the late fee for delayed GSTR-9?

₹50 per day (₹25 CGST + ₹25 SGST) up to ₹5 crore turnover, ₹100 per day between ₹5 crore and ₹20 crore, and ₹200 per day above ₹20 crore, subject to the caps under N/N 07/2023-CT.

What is the last date by which FY 2025-26 GSTR-9 can be filed at all?

31 December 2029. Under Sec. 44(2), the return cannot be filed after three years from its due date.

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