GSTR-9 & GSTR-9C for FY 2024-25

By CA Surekha S Ahuja

Why Annual GST Returns Have Become Continuity Statements — and How CAPS Now Judges Your Compliance

In the CAPS era, GST annual returns are not checked for totals.
They are tested for consistency, continuity, and credibility across years.

For many years, GSTR-9 and GSTR-9C were treated as summary compliance forms — annual compilations of what had already been reported in GSTR-1 and GSTR-3B.

That understanding is now outdated.

From FY 2024-25 onwards, the GST system processes annual returns through CAPS (Common Annual Processing System) — an internal GSTN framework that does behaviour-based reconciliation, not form-based validation.

The system no longer asks only:

“Is tax paid?”

It increasingly asks:

When was ITC claimed?
Why was it reversed or reclaimed?
How does this year connect with the previous and next year?

As a result, most GST notices today arise not due to tax short-payment, but due to broken table-to-table and year-to-year linkages.

This article explains how to file GSTR-9 and GSTR-9C for FY 2024-25 in a manner that is:

CAPS-aligned
cross-referenced
litigation-safe

The New Compliance Philosophy: Five Rules That Now Matter Most

Before diving into tables, it is important to internalise five governing principles that now shape annual GST scrutiny:

Every ITC must have a time identity
Whether it belongs to the current year, a prior year, or the next year must be clearly disclosed.
Every ITC movement must have a reason
Claim, reversal, reclaim, or permanent loss — silence is no longer acceptable.
Timing differences must be disclosed, not adjusted
Annual returns reward transparency, not cosmetic netting-off.
Cross-year continuity matters more than year-wise symmetry
A small difference is defensible if logically explained across years.
CAPS prefers explanation over perfection
Unexplained alignment is riskier than explained difference.

GSTR-9 for FY 2024-25: Understanding the Return as a System Narrative

Tables 4 & 5 — Outward Supplies: Where the Story Begins

Tables 4 and 5 establish the nature and taxability of turnover — taxable, exempt, nil-rated, non-GST, exports, and reverse charge supplies.

Why this matters under CAPS:

Table 4 & 5 must align with GSTR-1
They must logically flow into Table 9 (Tax Payable)
They must reconcile with GSTR-9C Table 5

Unexplained differences here often trigger turnover mismatch communications, even where tax is fully paid.

Table 6 — ITC Architecture (The Most Scrutinised Block)

Table 6A — ITC as per GSTR-3B (Auto-Populated)

This is the system’s starting point — the aggregate of ITC claimed through FY 2024-25 GSTR-3B returns.

Table 6A1 — Prior-Year ITC Claimed in FY 2024-25 (New from FY 24-25)

This table captures ITC relating to earlier financial years but claimed during FY 2024-25.

Why this table fundamentally changes ITC reporting:

It segregates past-year credit from current-year behaviour
It prevents inflation of FY 2024-25 ITC
It allows CAPS to track delayed claims cleanly

Table 6A2 — Net ITC of FY 2024-25

Computed as:

Table 6A – Table 6A1

This figure represents the true ITC behaviour of FY 2024-25 and becomes the anchor for GSTR-9C ITC reconciliation.

Tables 6B to 6D — Current-Year ITC Claims

These tables report first-time ITC claims pertaining to FY 2024-25.

Under CAPS, they are cross-verified with:

GSTR-2B (FY 2024-25)
Table 8B
GSTR-9C Table 12

Table 6H — ITC Reclaimed under Rule 37 / 37A

This is one of the highest-scrutiny tables in GSTR-9.

It reports restoration of ITC that was reversed earlier due to non-payment or similar rule-based conditions.

Critical clarity:

Reclaimed ITC is not fresh ITC
It must not be reported in Table 6B
It must never be reported in Table 8C

Incorrect placement here is a common trigger for automated scrutiny.

Table 7 — ITC Reversals (Including New Tables 7A1 & 7A2)

Table 7 reports reversals under:

Rule 37 / 37A
Rule 42 / 43
Section 17(5)

CAPS evaluates whether:

reversals follow a logical lifecycle, and
reclaims (if any) reappear in the correct year and table.

Permanent reversals (e.g., Section 17(5)) are treated very differently from temporary reversals.

Table 8 — ITC Reconciliation (CAPS Engine Room)

The system-computed formula is:

Table 8D = 8A – (8B + 8C)

Where:

8A is ITC as per GSTR-2B
8B is ITC claimed for FY 2024-25
8C is missed ITC of FY 2024-25 claimed in the next year

Important nuance (often misunderstood):

A negative 8D is not illegal
It is a risk indicator
What matters is whether the difference is logically explained elsewhere

Reclaimed ITC must never enter Table 8C.

Tables 10–13 — Where Timing Differences Are Explained

These tables disclose when tax or ITC was actually discharged, not whether it was correct.

Tables 10–11 → outward liability paid in FY 2025-26
Table 12 → ITC reversed in FY 2025-26
Table 13 → ITC availed in FY 2025-26

Golden rule:
Tables 12 and 13 are never netted off. They exist to preserve audit trail.

GSTR-9C: Reconciliation, Not Re-Audit

GSTR-9C remains a statutory reconciliation statement, not an audit certification.

Key anchors:

Turnover reconciliation → GSTR-9 Tables 4 & 5
Tax paid reconciliation → GSTR-9 Table 9
ITC reconciliation → GSTR-9 Table 6A2

Differences are expected.
What is required is clear narration, not forced elimination.

Why CAPS Changes Everything

CAPS does not read one return in isolation.

It connects:

previous year disclosures,
current year behaviour, and
next year claims.

From a system perspective, consistency tells a stronger compliance story than perfection.

Conclusion: The New Meaning of “Correct” in GST Annual Returns

For FY 2024-25, GSTR-9 and GSTR-9C are no longer about compiling numbers.
They are about telling a consistent, explainable story across years.

A return that shows:

where ITC came from,
why it moved, and
when it was claimed

is defensible — even with differences.

A return that breaks continuity is vulnerable — even when tax is fully paid.

In the CAPS era of GST, cross-reference is compliance.

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Friday, December 19, 2025