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GST Β· Annual Return

GSTR-9 and GSTR-9C for FY 2025-26: who files, due date and checklist

Turnover limits, the 31 December 2026 due date, the 30 November cut-off for ITC and credit notes, late fees, the three-year time bar, and the reconciliations to finish before you file.

By CA Dilbagh Singh, Chartered Accountant, Rohini, Delhi Β· Published 6 November 2026

GSTR-9 is the annual return in which a regular GST taxpayer reports, in one place, the outward supplies, tax paid and input tax credit for the whole financial year. GSTR-9C is the reconciliation statement that ties those figures to the audited or annual financial statements. Both are filed on the GST portal for each GSTIN, and for FY 2025-26 both are due by 31 December 2026.

Who must file

Aggregate turnover up to β‚Ή2 croreExempted from filing GSTR-9 by the yearly CBIC notification. You may still file voluntarily.Optional
Above β‚Ή2 crore and up to β‚Ή5 croreGSTR-9 is mandatory; GSTR-9C is not required.GSTR-9
Above β‚Ή5 croreGSTR-9 plus the self-certified reconciliation statement GSTR-9C. A CA's certification has not been required since FY 2020-21.GSTR-9 + 9C
Not requiredComposition taxpayers (they file GSTR-4), Input Service Distributors, casual and non-resident taxable persons, TDS deductors and TCS collectors, and OIDAR suppliers.Exempt

Aggregate turnover is worked out at PAN level – all GSTINs on the same PAN across India together – even though the return itself is filed GSTIN-wise.

Dates that matter now

Last date to claim FY 2025-26 ITCUnder Section 16(4) of the CGST Act, ITC on FY 2025-26 invoices can be claimed up to 30 November 2026 or the date of filing GSTR-9, whichever is earlier. Credit missed after that is lost.30 Nov 2026
Credit notes for FY 2025-26 suppliesUnder Section 34(2), a credit note for a FY 2025-26 supply must be declared by 30 November 2026 (or the date of the annual return, if earlier) to reduce your tax.30 Nov 2026
GSTR-9 and GSTR-9CAnnual return and reconciliation statement for FY 2025-26, unless extended by notification.31 Dec 2026

The GSTR-9 tile on the portal opens only once every GSTR-1 and GSTR-3B for the year has been filed, so clear any pending monthly or quarterly return first.

Reconcile before you file

GSTR-9 cannot be revised once filed, and its figures are now the starting point for scrutiny under ASMT-10 and demand notices. The work is in the reconciliations:

  • Books vs GSTR-1 vs GSTR-3B – outward supplies, rate-wise and month-wise, including amendments made in later months.
  • ITC in GSTR-3B vs GSTR-2B – supplier-wise, with reasons for every difference (Table 8 of GSTR-9 shows this to the officer automatically).
  • Reversals – ITC reversed under Rules 37, 37A, 42 and 43 and Section 17(5), and any reclaimed credit, reported in the right tables.
  • Reverse charge – RCM paid and the matching ITC on legal fees, GTA, rent from unregistered persons and imports of services.
  • Spill-over entries – FY 2025-26 transactions declared in returns from April to October/November 2026 go in Part V (Tables 10–14).
  • HSN summary – Table 17/18 HSN-wise details should agree with the HSN reported in GSTR-1.
  • Short payment – any tax found short should be paid through DRC-03 with interest before filing, rather than left for a notice.

For GSTR-9C, also reconcile turnover in the financial statements with GSTR-9 – unbilled revenue, advances, credit notes, deemed supplies and branch transfers are the usual differences.

Late fee and time bar

Turnover up to β‚Ή5 croreβ‚Ή50 per day (β‚Ή25 CGST + β‚Ή25 SGST), capped at 0.04% of turnover in the State/UT.Sec 47
Above β‚Ή5 crore up to β‚Ή20 croreβ‚Ή100 per day, capped at 0.04% of turnover in the State/UT.Sec 47
Above β‚Ή20 croreβ‚Ή200 per day, capped at 0.5% of turnover in the State/UT.Sec 47
Three-year time barAn annual return cannot be filed after three years from its due date, so a missed GSTR-9 can become permanently unfileable.Sec 44

This article is general information, not advice for your specific case. Forms, limits and due dates can change through notifications and circulars – check the current law, or speak to us before you act.

Frequently asked questions

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

31 December 2026, unless the government extends it by notification. GSTR-9C has the same due date.

Is GSTR-9 mandatory if my turnover is below β‚Ή2 crore?

No. Taxpayers with aggregate turnover up to β‚Ή2 crore are exempted by the yearly CBIC notification, though they may file voluntarily.

Who has to file GSTR-9C?

Registered persons whose aggregate turnover for the year exceeds β‚Ή5 crore. GSTR-9C is self-certified; CA certification is no longer required.

Can I claim missed FY 2025-26 ITC in GSTR-9?

No. GSTR-9 is only a statement. Missed ITC has to be claimed in a GSTR-3B filed by 30 November 2026 (or before you file GSTR-9, if earlier).

Can GSTR-9 be revised after filing?

No. There is no option to revise GSTR-9, so complete your reconciliations before you file.

Have a tax, GST or business question?

Call, WhatsApp or email CA Dilbagh Singh and team, from Delhi, anywhere in India or abroad.

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