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 TurnoverGSTR-9 RequiredGSTR-9C Required
Up to ₹2 croreOptional (filing exempted)No
₹2 crore – ₹5 croreYes — mandatoryNo (self-certified reconciliation optional)
Above ₹5 croreYes — mandatoryYes — mandatory (CA-certified reconciliation)

GSTR-9 / 9C Process Stages and Checklist

Stage 1: Data Collection (October – November)

TaskData SourceStatus
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 booksTally / accounting software☐
GSTR-2B for all 12 monthsGST portal auto-drafted☐
Credit notes, debit notes (B2B)GSTR-1 amendments + books☐
RCM payable and RCM ITC claimedGSTR-3B + books☐

Stage 2: Reconciliation (November)

Reconciliation TaskExpected OutcomeStatus
Turnover per GSTR-1 vs booksMatch or explainable difference (B2C adj., exempt supply)☐
Tax paid per GSTR-3B vs tax liability per booksMatch; identify any underpaid / overpaid amounts☐
ITC per GSTR-3B vs GSTR-2BReconcile; flag ineligible ITC claimed☐
ITC per books vs ITC per GSTR-3BIdentify ITC not claimed (eligible for GSTR-9 claim)☐
Pending ITC reversal obligationsRule 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 StepResponsibleStatus
Review reconciliation differences — any unexplained difference > 1% of turnoverPartner / Manager☐
Check tax payable in Table 10 — arrange payment before filingClient + CA☐
File GSTR-9 on GST portalSenior Article / Manager under CA supervision☐
File GSTR-9C (if applicable); generate UDINPartner CA☐
Download and archive GSTR-9/9C acknowledgmentAdmin☐

TaxZeo's GSTR-9 workflow tracks every client's stage — from data collection to filing confirmation — with team-level visibility across all clients simultaneously.

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Frequently 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.