DECEMBER 24, 2025

GSTR 9 Extension: The Annual Return of Anxiety

By Vijay Kumar

INDIA's taxpayers didn't ask for a Rubik's cube; they got GSTR-9.

The Bombay Chartered Accountants' Society (BCAS), a venerable 75-year-old institution of sober accountants and unsleeping spreadsheets, has written to Finance Minister Nirmala Sitharaman and the GST mandarins with a modest plea:

Extend the due date for filing GSTR-9 and GSTR-9C.

Not because accountants love extensions (though they do), but because this year's annual return has been rewired so many times it resembles a Delhi traffic signal-always changing, never predictable.

So, what's in this annual return that has the nation's tax teams pacing the floor?

In short: everything you did all year-purchases, sales, ITC claimed, reversed, reclaimed, imports, and that never-ending reconciliation between what you booked and what the system thinks you booked.

It was supposed to be consolidation. This year, it feels like reconstruction.

What is this Form GSTR-9 that worries GST payers all over India. The Board has clarified:

1. What is Form GSTR-9?

Form GSTR-9 is an annual return to be filed once for each financial year, by the registered taxpayers. They are required to furnish details of purchases, sales, input tax credit or refund claimed or demand created etc. in this return.

2. Who need to file Annual Return in Form GSTR-9?

Form GSTR-9 is to be filed by a person who is registered as a normal taxpayer, including SEZ unit or SEZ developer.

3. What is the difference between Form GSTR-9 and Form GSTR-9C?

Form GSTR-9 is required to be filed by every person registered as normal taxpayer. However, certain class of taxpayers may be exempted from filing Form GSTR-9. Form GSTR-9C is required to be filed by every registered person whose aggregate turnover is above a certain threshold during the financial year, as notified. They are required to get their accounts audited by Chartered Accountant or Cost Accountant and need to submit a copy of audited annual accounts and reconciliation statement.

4. Is it mandatory to file Form GSTR-9?

Yes, it's mandatory to file Form GSTR-9 for normal taxpayers. It may, however, be made optional for taxpayers having AATO up to a certain threshold, from time to time.

AATO stands for Annual Aggregate Turn Over.

Now the BCAS that is the BOMBAY CHARTERED ACCOUNTANTS' SOCIETY submits to the Government that:

1. Significant practical and technical challenges are being faced by taxpayers and tax professionals in complying with the annual return for the Financial Year 2024-25 mostly because of the substantial amendments introduced in FORM GSTR-9 (Annual Return) and FORM GSTR-9C (Reconciliation Statement), primarily through notifications (12/2024-CT and 13/2025-CT).

2. This constant evolution, while aimed at improvement, creates a moving target for compliance. It demands that taxpayers and professionals perpetually adapt their data management systems, reconciliation processes, and reporting software.

3. While the annual return is intended to consolidate the monthly or quarterly filings, the recent amendments represent a fundamental policy shift. They revoke long-standing practical relaxations that the industry had built processes around for several years, introducing new layers of complexity that far exceed simple aggregation.

The real difficulties:

1. The taxpayers are required to maintain a new, complex data tracker to segregate prior-period ITC from current-period ITC and further distinguish it from specific types of reclaimed credits. It breaks the traditional flow of ITC reconciliation.

2. They are required to make a detailed, retrospective analysis of all ITC reversals made during the year to map them to the specific rule under which they were made. For many, this data was not tracked with such granularity, requiring a significant manual effort.

3. The lifecycle of a single credit (claim, reversal, reclaim) must now be tracked and reported across different tables (6B, 7, and 6H), increasing the risk of reporting errors and mismatches.

4. An additional reconciliation point for import transactions is created, forcing taxpayers to meticulously track Bill of Entry dates against the period of ITC availment in FORM GSTR-3B.

5. The taxpayers are forced to perform an entirely new, year-specific ITC reconciliation for each GSTIN. They must now filter their GSTR-2B data to exclude any prior-year invoices that may appear in the current year's statements.

6. There is a new layer of analytical work to an already complex process.

7. The users are also experiencing the technical glitches on the GST portal as a result of which after filing the Annual Return the auto populated figures in Table 8A are captured as Nil.

8. A complete re-engineering of existing reconciliation workbooks and processes is required that have been used for years, demanding a thorough understanding of the new data flow to ensure an accurate annual return.

9. These challenges are not limited to GSTR-9 but extend with equal, if not greater, complexity to the GSTR-9C reconciliation statement.

Even clarifications are challenging.

The BCAS represented that three FAQs have been issued so far, for FY 2024-25 (the latest one being issued on 4/12/2025.) When significant changes are introduced late in the compliance cycle, subsequent clarifications, even those issued in rapid succession, add to the administrative burden and lead to delays as professionals and taxpayers must first absorb the new legal provisions and then interpret the clarification.

The Request:

In light of the substantial and complex amendments, on behalf of the members of the Bombay Chartered Accountants Society and the wider taxpayer community, they have formally and respectfully requested a general extension for the filing of FORM GSTR-9 and FORM GSTR-9C for the Financial Year 2024-25. They proposed an extension of the due date by at least three months for all taxpayers.

Justification

Such an extension is crucial to allow taxpayers and professionals sufficient time to absorb these significant procedural changes, ensure data accuracy, undertake necessary system upgrades, and fulfil their compliance obligations correctly. Granting this request will foster a more accurate, less error-prone filing season, which is in the best interest of both the government and the taxpayers.

This seems to be the problem of thousands of taxpayers. Should compliance and complicated forms make taxpaying such a tangled maze?

While the BCAS has compiled all the difficulties, several taxpayers complain that:

1. Downloading of data shown in Table 8A of GSTR 9 and reconciliation with summary details (Online) available – Cumbersome and time-consuming process

a. Table 8A data is currently downloaded in multiple buckets, and where the number of line items is large, the data is received in several files of limited size. Collating this data into a single consolidated file is a cumbersome and time-consuming process. However, such downloading and collation are necessary, as the data is required to be reconciled with GSTR-2B, which is downloaded separately.

b. Further, two different amounts appear in Table 8A-one in the online view and downloaded details. Downloading and reconciling both sets of data is essential to verify data sanity, as in several cases the figures do not reconcile even after making all adjustments as prescribed in the advisory.

c. Overall, the current process of downloading data in multiple files and manually collating it into a single usable format is cumbersome, time-consuming.

2. Data bifurcation in multiple years i.e. 2023-24, 2024-25 and 2025-26.

a. There is a requirement to bifurcate the entire purchase register duly reconciled with GSTR-2B into multiple financial years for the purpose of correct reporting in various tables of GSTR-9, namely Tables 6 including 6A (1), 7, and 8, along with Tables 12 and 13. This exercise itself is highly detailed and time-consuming.

b. Further, reconciliation between Table 8A of GSTR-9 and the details downloaded from GSTR-2B is a mammoth task. It is pertinent to note that from FY 2024-25 onwards, the auto-population of Table 8A has been shifted to the document date, irrespective of the GSTR-2B period. Accordingly, invoices are auto populated in Table 8A even if they are reported by suppliers up to October of the subsequent financial year.

c. At the same time, if any documents pertaining to previous financial years are reflected in the GSTR-2B of the current financial year, the same are not auto-populated in Table 8A. Therefore, it is to be reported separately in table 6A (1). This fundamental change in logic compels to perform a fresh, year-specific ITC reconciliation for each GSTIN.

d. As a result, it is now required to filter GSTR-2B data to exclude invoices pertaining to prior financial years that appear in the current year's GSTR-2B. This additional filtering and validation layer significantly increases the analytical effort involved in an already complex reconciliation process.

3. Certain disclosures (like Table 12 and 13) that were previously optional have now been made mandatory. This change necessitates a significantly higher level of data sanitisation across all stages of data preparation, validation, and reporting.

The reasonable request

They are not asking for a tax holiday in Goa. Just three months. Enough to absorb the changes, sanitize the data, recalibrate the systems, and file without collapsing. Accuracy is the government's goal; clarity is the taxpayer's dream. Time is the bridge.

Should compliance feel like a knotty puzzle? Or should it feel like paying taxes-painful but straightforward? Right now, taxpayers are wondering if they should file returns or file writ petitions.

Maybe we can have a test.

Let CBIC officers try filing GSTR - 9 for a top company. If they finish in two days, fine. If not, grant the extension. After all, if the makers can't solve their own puzzle, why expect the players to?

A simple stress test for the system

Hope, with a deadline

There's a week left. A timely, quiet order could save a noisy litigation season. If the ministry grants the extension, let's thank the Finance Minister in advance-because gratitude filed early is one return that never gets rejected.

If extensions are the taxpayers' survival kit, granting one would be the government's easiest New Year gift.