In this guide
GSTR-9 and GSTR-9C, where applicable, are ordinarily due on December 31, 2026 for FY 2025-26, unless extended by an applicable government notification.
GSTR-9 summarises annual GST transactions. GSTR-9C reconciles the annual return with audited annual financial statements. Before filing, check your turnover threshold, complete outstanding returns and investigate discrepancies between your books and GST records.
Who Must File GSTR-9 and GSTR-9C?
For regular taxpayers otherwise covered by the annual-return requirements:
| Aggregate turnover in FY 2025-26 | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Exempt | Not required |
| Above ₹2 crore and up to ₹5 crore | Required | Not required |
| Above ₹5 crore | Required | Required |
Notification No. 15/2025–Central Tax exempts registered persons with aggregate turnover up to ₹2 crore from annual-return filing for FY 2024-25 onwards. The exemption therefore applies to FY 2025-26.
GSTR-9C is not required at exactly ₹5 crore turnover; turnover must exceed ₹5 crore.
Calculate turnover across the same PAN
Aggregate turnover is calculated across India for registrations under the same PAN. It generally includes taxable supplies, exempt supplies, exports and inter-State supplies. It excludes GST and inward supplies on which tax is payable under reverse charge.
The applicability threshold is tested across the PAN, but filing is GSTIN-wise.
For example, a business with ₹3 crore turnover in Maharashtra and ₹3 crore in Karnataka has ₹6 crore aggregate turnover. Both regular registrations generally require GSTR-9 and GSTR-9C.
Who follows different requirements?
GSTR-9 is not the annual filing form for composition taxpayers. Input Service Distributors, persons registered solely for TDS or TCS, casual taxable persons and non-resident taxable persons are also outside the ordinary GSTR-9 requirement.
Specified government departments and local authorities may qualify for exemptions. A business that changed its registration type during the year should check the requirements for each period.
GSTR-9 vs GSTR-9C
GSTR-9 brings together outward supplies, input tax credit, tax paid and other annual disclosures.
GSTR-9C explains differences between the annual return and audited annual financial statements, including turnover, tax and ITC reconciliation.
GSTR-9C is a self-certified reconciliation statement. The earlier GST audit framework required separate certification by a chartered accountant or cost accountant; that requirement no longer applies. Audit requirements under other laws remain separate.
What to Prepare Before Filing
Have the following ready:
- FY 2025-26 financial statements and trial balance;
- Sales, purchase and credit/debit-note registers;
- Filed GSTR-1, applicable GSTR-1A and GSTR-3B records;
- GSTR-2B data and available annual ITC downloads;
- Export, SEZ and reverse-charge records;
- ITC reversal and reclaim workings;
- Tax-payment, refund and demand details;
- GSTIN-wise allocation workings for businesses with multiple registrations.
Use TaxClear’s account-finalisation checklist to organise the underlying reconciliation.
Step-by-Step Filing Guide
1. Complete outstanding periodic returns
Make sure all required GSTR-1 and GSTR-3B returns for FY 2025-26 have been filed. Pending returns can prevent annual-return preparation or filing.
2. Open the annual-return dashboard
Log in to the GST Portal and go to Services → Returns → Annual Return. Select FY 2025-26 and open GSTR-9.
Download the available system summaries and draft return before making changes.
3. Reconcile turnover and tax
Compare books with outward-supply returns and GSTR-3B. Check missing invoices, amendments, credit notes, exports and timing differences.
Do not assume figures are accurate simply because the portal auto-populated them.
4. Review ITC carefully
Separate eligible credit, blocked credit, reversals, reclaims and transactions relating to another financial year.
Follow the notified instructions and portal guidance for FY 2025-26. Avoid copying previous-year table treatment without checking applicability.
TaxClear’s GSTR-2B and IMS reconciliation guide can help identify invoice-level differences.
5. Preview and file GSTR-9
Check all applicable tables, compute liabilities and pay applicable late fees. File using the permitted DSC or EVC method and retain the ARN and filed return.
Additional liability identified during annual reconciliation should be discharged through the appropriate DRC-03 process, including applicable interest.
6. Complete GSTR-9C where required
After filing GSTR-9, prepare the reconciliation statement, explain differences, upload the required financial statements and complete taxpayer certification.
Where GSTR-9C is mandatory, ensure that both forms show “Filed”.
Important Cautions
- GSTR-9 cannot be revised after filing. Review figures before submission.
- Fresh ITC cannot be claimed through GSTR-9.
- The ordinary Section 16(4) deadline for FY 2025-26 invoice/debit-note ITC is November 30, 2026 or filing the relevant annual return, whichever is earlier, subject to applicable exceptions.
- Filing GSTR-9 alone is insufficient where GSTR-9C is required. Late fees can continue until the complete annual return is furnished.
- Late-fee rates and caps vary by turnover category and applicable notification; there is no universal flat amount for every taxpayer.
For reconciliation and filing assistance, contact TaxClear’s GST services team.
Frequently Asked Questions
Is GSTR-9 required at exactly ₹2 crore turnover?
No. The exemption covers aggregate turnover up to ₹2 crore.
Is GSTR-9C required at exactly ₹5 crore turnover?
No. Turnover must exceed ₹5 crore.
Does self-certification remove all audit requirements?
No. Audit requirements under company, LLP and income-tax law remain separate.
Can missed ITC be claimed through GSTR-9?
No. Eligible credit must be claimed through the appropriate return within the applicable legal time limit.
Does filing GSTR-9 complete compliance if GSTR-9C applies?
No. Both forms must be furnished to complete the annual-return obligation.
