GSTR-9 (annual return) and GSTR-9C (reconciliation statement) have a December 31 deadline for FY 2025-26. For CA firms with 30+ GST clients, managing this across a team without a structured tracking system leads to last-week panic and filing errors. This checklist covers every stage of the GSTR-9/9C process from data collection to filing confirmation.
Who Needs to File GSTR-9 and GSTR-9C for FY 2025-26?
| Annual Turnover | GSTR-9 Required | GSTR-9C Required |
|---|---|---|
| Up to ₹2 crore | Optional (filing exempted) | No |
| ₹2 crore – ₹5 crore | Yes — mandatory | No (self-certified reconciliation optional) |
| Above ₹5 crore | Yes — mandatory | Yes — mandatory (CA-certified reconciliation) |
GSTR-9 / 9C Process Stages and Checklist
Stage 1: Data Collection (October – November)
| Task | Data Source | Status |
|---|---|---|
| All monthly GSTR-1 data (B2B, B2C, exports, amendments) | GST portal / client records | ☐ |
| All monthly GSTR-3B data (outward supplies, ITC claimed, tax paid) | GST portal returns | ☐ |
| Annual sales as per books of accounts (financials) | Tally / accounting software | ☐ |
| Annual purchase and ITC as per books | Tally / accounting software | ☐ |
| GSTR-2B for all 12 months | GST portal auto-drafted | ☐ |
| Credit notes, debit notes (B2B) | GSTR-1 amendments + books | ☐ |
| RCM payable and RCM ITC claimed | GSTR-3B + books | ☐ |
Stage 2: Reconciliation (November)
| Reconciliation Task | Expected Outcome | Status |
|---|---|---|
| Turnover per GSTR-1 vs books | Match or explainable difference (B2C adj., exempt supply) | ☐ |
| Tax paid per GSTR-3B vs tax liability per books | Match; identify any underpaid / overpaid amounts | ☐ |
| ITC per GSTR-3B vs GSTR-2B | Reconcile; flag ineligible ITC claimed | ☐ |
| ITC per books vs ITC per GSTR-3B | Identify ITC not claimed (eligible for GSTR-9 claim) | ☐ |
| Pending ITC reversal obligations | Rule 37, Rule 42/43 reversal working | ☐ |
Stage 3: GSTR-9 Draft Preparation
- Table 4: Outward supplies declared during FY (from GSTR-1 totals)
- Table 6: ITC availed as declared in GSTR-3B
- Table 7: ITC reversed and ineligible ITC (Rule 37, 42, 43 reversals)
- Table 10/11: Tax paid / additional tax payable after annual reconciliation
- Table 14/15: HSN summary (outward and inward supplies)
Stage 4: GSTR-9C (for turnover > ₹5 crore only)
- Part A: Reconciliation of turnover declared in audited financials vs GST returns
- Part B: Reconciliation of ITC availed vs ITC as per audited books
- CA certification in Part C — requires CA's DSC and UDIN generation
- Upload in GST portal only after GSTR-9 is filed
Stage 5: Partner Review and Filing
| Review Step | Responsible | Status |
|---|---|---|
| Review reconciliation differences — any unexplained difference > 1% of turnover | Partner / Manager | ☐ |
| Check tax payable in Table 10 — arrange payment before filing | Client + CA | ☐ |
| File GSTR-9 on GST portal | Senior Article / Manager under CA supervision | ☐ |
| File GSTR-9C (if applicable); generate UDIN | Partner CA | ☐ |
| Download and archive GSTR-9/9C acknowledgment | Admin | ☐ |
TaxZeo's GSTR-9 workflow tracks every client's stage — from data collection to filing confirmation — with team-level visibility across all clients simultaneously.
Start Free TrialFrequently Asked Questions
Can ITC missed in monthly GSTR-3B be claimed in GSTR-9?
Yes, within limits. GSTR-9 Table 13 allows claiming ITC that was not claimed in the respective monthly returns but was reflected in GSTR-2B. However, the deadline is the earlier of: (a) the due date for filing GSTR-9 for that year, or (b) October 31 of the following year. For FY 2025-26, this means ITC not claimed in FY 2025-26 GSTR-3B returns can be claimed in GSTR-9 (due December 31, 2026) subject to the GSTR-2B match. ITC that was not in GSTR-2B cannot be claimed through GSTR-9.
Is GSTR-9 filing mandatory for a composition taxpayer?
No. Composition taxpayers file GSTR-4 (annual return) instead of GSTR-9. GSTR-9 applies only to taxpayers registered under the regular scheme. If a business switched from composition to regular scheme mid-year, they would file GSTR-4 for the composition period and GSTR-9 for the regular scheme period. Advise clients who switched schemes in FY 2025-26 to check with you before assuming which return applies.