GSTR-9 and 9C filing: What businesses must know about new ITC disclosure rules

With the GSTR-9 and GSTR-9C filing window for FY 2024–25 now open, tax professionals are analysing the detailed FAQs released by the Goods and Services Tax Network (GSTN) to understand their practical impact on annual compliance.

According to tax experts, the clarifications around Input Tax Credit (ITC) reporting — particularly in Tables 6, 7, 8 and the newly introduced 8H1 — are expected to significantly influence how businesses approach reconciliation this year.

Sandeep Sehgal, Partner–Tax at AKM Global, said that while the FAQs address long-standing confusion, they also raise new compliance checkpoints.

“The granular instructions on how to classify ITC reversals and reclaims under Rules 37 and 37A — depending on whether they relate to the current or previous financial year — will require careful ledger tracking,” Sehgal noted. “Even the variance between Table 8A as shown online versus in Excel needs manual intervention using the supporting document download utility.”

Key takeaways from practitioner lens

New Table 8H1 may trigger additional disclosures for businesses importing goods where ITC was deferred to the next financial year.

Table 6M realignment, now clubbing ITC from Forms ITC-01/02/02A, could simplify reporting for entities undergoing transfers or reorganisations, but requires back-end data classification.

Table 17 on Late Fee in GSTR-9C could standardise computation, though many filers are still unsure whether portal auto-calculation will override manual entries.

Cross-year ITC in Table 13 — where ITC of FY 2024–25 availed in FY 2025–26 has to be disclosed — continues to be an area prone to mismatch with GSTR-2B.

Compliance advisory: Start reconciliation early

With auto-populated ITC figures now drawing not just from FY 2024–25 filings but also from amendments made up to October 2025, experts say businesses should begin ledger alignment immediately rather than waiting closer to the due date.

“Even though the forms are technically the same, the disclosures are becoming increasingly forensic,” Sehgal said. “This year’s annual return will not be a mere summarisation exercise — it’s a test of consistency between GSTR-3B, GSTR-2B and internal books.”