Major Amendments in GSTR-9 and GSTR-9C for FY 2024-25 Based on ICAI Suggestions
For FY 2024–25, significant modifications have been made to the annual GST return Form GSTR-9 and the reconciliation statement Form GSTR-9C through Notification No. 13/2025-Central Tax dated 17-09-2025. These amendments are largely based on the technical recommendations submitted by the Institute of Chartered Accountants of India (ICAI).
The revised formats and instructions aim to:
- Align the forms more closely with the substantive provisions of GST law
- Reduce mismatches between books and returns
- Avoid wrongful lapsing of Input Tax Credit (ITC)
- Provide clearer and more granular reporting of tax liabilities and payments
Below is a structured analysis of each key suggestion of ICAI and how it has been incorporated in the amended forms.
1. Allowing Payment of Additional Tax Liability via ITC in GSTR-9
Background
Earlier, the instructions to Form GSTR-9 were interpreted in a way that additional tax liability disclosed in the annual return was to be discharged primarily through the electronic cash ledger, creating an impression that utilisation of ITC for this purpose was restricted, despite the GST law permitting payment through the electronic credit ledger as well.
ICAI’s Suggestion
ICAI recommended amendment of Para 9 of the Instructions to Form GSTR-9 so that it explicitly allows the assessee to pay any additional liability declared in the annual return through:
- Electronic cash ledger, or
- Electronic credit ledger
Amendment Accepted
The suggestion has been implemented. The relevant instruction now clearly states:
“It may be noted that such liability shall be paid through electronic cash ledger or electronic credit ledger.”
Impact on assessee:
- Assessee can utilise available ITC balance to discharge additional liability reported in
GSTR-9. - Better cash flow management, as unnecessary cash outflow is avoided.
- Legal position under the GST law and the form instructions are now aligned.
2. Reporting of Tax Paid via ITC in GSTR-9C
Issue in Earlier Format
In Form GSTR-9C, particularly in Table 11 and Part V, the headers previously focused on liability “to be paid through Cash”, which created ambiguity or limitation in showing tax paid via ITC.
ICAI’s Suggestion
ICAI proposed modification of:
- Table 11
- Part V of
Form GSTR-9C
so that these clearly allow reporting of tax payable and paid either through cash or through ITC, and not cash alone.
Amendment Accepted
The Government has updated the headers in Table 11 and Part V from:
- “To be paid through Cash”
to - “To be paid through cash or ITC.”
Practical outcome:
- GSTR-9C now reflects the actual mode of payment—cash and/or ITC.
- Ensures accurate reconciliation between books, GSTR-9, and payment ledgers.
- Provides a more realistic picture of tax discharge for audit and verification.
3. Separate Disclosure of IGST Credit on Imports in GSTR-9
Pre-Amendment Problem
In Table 8 of Form GSTR-9, Table 8H was used for reporting IGST credit on imports not availed in the year. However, where such IGST credit was availed in the next financial year, it would still appear as “lapsed” in Table 8K, distorting the true position and potentially creating audit and departmental queries.
ICAI’s Suggestion
ICAI suggested splitting Table 8H into two parts to separately disclose:
- IGST credit on imports not availed and not claimed later, and