Bird eye view on strategies for preparing the Annual Return
Year-wise applicability of Table of GSTR-9 and GSTR-9C
Amendments and key considerations while performing the working for
Locator of various topics in this Book
Illustrative requirements for preparing GSTR-9 and GSTR-9C
Illustrative checklist for GSTR 9 and GSTR 9C
List of Governing provisions of GSTR-9 and GSTR-9C Annual Return and reconciliation
Part I of GSTR-9: Basic details
Part II of GSTR-9: Details of outward and inward supplies declared during the financial year
Part III of GSTR-9: Details of ITC for the financial year during the financial year
Part V: Particulars of the transactions for the financial year declared in returns of the next financial year till the specified period
Part VI: Other Information
GSTR-9A: Is it really applicable and basics of annual return
Part I of GSTR-9A: Basic Details
Part II of Form 9A: Details of outward and inward supplies declared in returns filed during the financial year
Part III: Details of tax paid as declared in returns filed during the financial year
Part IV : Particulars of the transactions for the previous FY declared in returns of april to september of current FY or upto date of filing of annual return of previous FY whichever is earlier
Your steps for preparing GSTR-9C
CONTENTS
Basics of reconciliation statement with practical issues
Part I of reconciliation statement: Basic details
Part II of reconciliation statement: Reconciliation of turnover declared in audited annual financial statement with turnover declared in
Part III: Reconciliation of tax paid
Part V: Additional liability due to non-reconciliation
APPENDICES
Form GSTR-9
Form GSTR-9A
Form GSTR-9C
Advisory on difference in value of Tables 8A and 8C of Annual Returns FY 2023-24
GSTN Clarification: Issues reported in filing Form GSTR-9C by the taxpayers
Clarification regarding Annual Returns and reconciliation statement
Clarification regarding optional filing of annual return under
Clarification by GST Network on 17-8-2020 on Table 8A of Form GSTR-9
CONTENTS
Letter of acceptance given by professionals for compilation engagement and responsibility of management
Engagement Letter
Appointment Letter
Cover Letter of Compilation Report
Compilation Report
CASE STUDY ON ITC IN GSTR-9 5 CHAPTER
Authors’Note- Registered person has to be very cautious in declaration of ITC in GSTR9 since department is using it as final summary for a particular FY. We have included 2 Case Studies based on amended position wherein first case study is for analysing the spillover transactions and second case study is for declaration of ITC - Availment, Reversal and Reclaim.
GST Network has issued FAQs on GSTR-9/9C for FY 2024-25 dated 16th October 2025 to guide that how annual return is to be prepared. Though this set of FAQs do not have any binding effect, still one may take a benefit of their guidance
CASE STUDY-1- ANALYSING THE EFFECT OF SPILLOVER TRANSACTIONS W.R.T. ITC
0ITC as per Books (Actual Eligible) of 2024-25 180
1ITC reflected in GSTR-2B of FY 2024-25175Invoice dated from previous Year and Invoice dated from current year reflected in GSTR2B of 2024-25
2ITC availed as per GSTR-3B of FY 2024-25175S. No. (3+4+6)
3ITC of 2023-24 reflected in GSTR-2B of 2024-2520ITC of Books reflected in GSTR-2B
4ITC of 2024-25 reflected in GSTR-2B of 2024-25150
5ITC of 2024-25 reflected in GSTR-2B of 2025-2630*
6ITC of 2023-24 (Reflected in GSTR-2B of 2023-24) availed in GSTR-3B of 2024-25
7ITC of 2023-24 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2024-25
8ITC of 2024-25 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2024-25
9ITC of 2024-25 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2025-26
5Table 6A1 of GSTR-9
20Table 6B of GSTR-9
150Table 6B of GSTR-9
5Table 8C of GSTR-9
S.No.ParticularsAmountRemarks
10ITC of 2024-25 (Reflected in GSTR-2B of 2025-26) availed in GSTR-3B of 2025-26 30**No action
Step2-DetailstobedeclaredinGSTR-9ofthecase
S.No.ParticularsAmountRemarks
6ATotal amount of input tax credit availed through FORM GSTR-3B (Sum total of table 4A of FORM GSTR-3B) 175
6A1*ITC of preceding financial year availed in the financial year (which is included in 6A above) other than ITC reclaimed under rule 37 and rule 37A
5
6A2*Net ITC of the financial year =(A-A1)170
6BInward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) 170
6HAmount of ITC reclaimed under the provisions of the Act
7ITC Reversal
8AITC as per GSTR-2B (Tables 3 & 5 thereof)175
8B*ITC as per sum total 6(B) above170
8CITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next financial year upto specified period 5
8DDifference [A-(B+C)]0
12*ITC of the financial year reversed in the next financial year
13*ITC of the financial year availed in the next financial year 5
* Shows the amended tables of GSTR-9 of FY 2024-25 onwards.
CASE STUDY-2- ANALYSING THE EFFECT OF ITC - AVAILMENT, REVERSAL AND RECLAIM.
IllustrationofITCClaim,ReversalandReclaim(WithComparison-Nowand Then)withAmendmentintroducedin vide NotificationNo.13/2025-CT,Dated 17-9-2025)
Step1-CollectionofFactsinbelowmanner.
S.No.ParticularsTablePositioning
1 ReversalofITCinCY2024-252023-24
1.1Reversal of ITC due to rule 37 or 37A
1.1.1Reversal of ITC which was availed in PY 7A/7A17A/7H1
S.No.ParticularsTablePositioning
1.1.2Reversal of ITC which is availed in CY 7A/7A17A/7H1
1.2Reversal of ITC due to other than rule 37 or 37A
1.2.1Reversal of ITC which was availed in PY
1.2.2Reversal of ITC which is availed in CY 2ReclaimofITCinCY2024-252023-24
2.1Reclaim of ITC reversed due to rule 37 or 37A
2.1.1Reclaim of ITC which was reversed in PY 6H6H
2.1.2Reclaim of ITC which is reversed in CY 6H6H
2.2Reclaim of ITC reversed due to other than rule 37 or 37A
2.2.1Reclaim of ITC which was reversed in PY 6A16H
2.2.2Reclaim of ITC which is reversed in CY 6H6H
Step2-DetailstobedeclaredinGSTR-9ofthecase
AmountTablePositioning
S.No.Particulars2024-252023-242024-252023-24
0.1ITC as per GSTR-2B of 2024-25 8001000
0.2ITC reflected in GSTR-2B of 2023-24 but availed in 2024-25
0.3ITC reflected in GSTR 2B of 2024-25 but availed in 2025-26
1Gross ITC Availed in GSTR 3B in 2024-25 1000 1200 6A6A
2.1.1Reversal of ITC which was availed in 2023-24 70270 7A/7A17A/7H1
2.1.2Reversal of ITC which is availed in 2024-25 130130 7A/7A17A/7H1
2.2Reversal of ITC due to other than rule 37 or 37A 150 350
2.2.1Reversal of ITC which was availed in 2023-24 40240 7H17H1
2.2.2Reversal of ITC which is availed in 2024-25 110110 7H17H1
S.No.Particulars2024-252023-242024-252023-24
3ReclaimofITCinFY2024-25200 400
3.1Reclaim of ITC reversed due to rule 37 or 37A 120 320
3.1.1Reclaim of ITC which was reversed in 2023-24 70270 6H6H
3.1.2Reclaim of ITC which is reversed in 2024-25 5050 6H6H
3.2Reclaim of ITC reversed due to other than rule 37 or 37A 80 280
3.2.1Reclaim of ITC which was reversed in 2023-24 20220 6A16H
3.2.2Reclaim of ITC which is reversed in 2024-25 6060 6H6H
6ATotal amount of input tax credit availed through FORM GSTR-3B (Sum total of table 4A of FORM GSTR-3B)
6A1*ITC of preceding financial year availed in the financial year (which is included in 6A above) other than ITC reclaimed under rule 37 and rule 37A
6A2*Net ITC of the financial year = (A-A1) 980980
6BInward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) 8001000
6HAmount of ITC reclaimed under the provisions of the Act 180380
7ITC Reversal 350750 630630
8AITC as per GSTR-2B (Tables 3 & 5 thereof) 8001000
8B *ITC as per sum total 6B above (Note- FY 2024-25 onwards it is just an auto-populated data of table 6B; for GSTR-9 of preceding FYs, it was the sum total of 6B and 6H)
AmountTablePositioning
S.No.Particulars2024-252023-242024-252023-24
8CITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next financial year upto specified period
8DDifference [A-(B+C)] 00
12*ITC of the financial year reversed in the next financial year 00
13*ITC of the financial year availed in the next financial year 00
* Shows the amended tables of GSTR-9 of FY 2024-25 onwards.
CHAPTER
WALKTHROUGH FOR PROFESSIONALS TO PERFORM GSTR-9/9A/9C
Authors’Note: Even after the omission of the GST Audit Provision u/s 35(5), still the role of a professional exists. In case where a professional is requested to compile the annual return and reconciliation statement, professional is required to be adhered with the set of principles.
For the sake of discussion to understand the role and responsibilities of management and professional, we are referring to the provisions of CA Act and Engagement and Quality Control Standards.
It may be noted that the professional is not required to perform attestation services as requirement of GST audit does not remain in existence w.e.f. FY 2020-21. So, the issue arises whether a professional has to follow the standard prescribing any set of procedures.
Before understanding the applicability of standard for the assignment supposed to be performed by a CA, it is pertinent to refer the provision of CA Act, 1949.
As per clause (7) of the Second Schedule of CA Act, A chartered accountant in practice shall be deemed to be guilty of professional misconduct, if he does not exercise due diligence, or is grossly negligent in the conduct of his professional duties. (Kindly note that on similar lines, the provisions are there for Company Secretary and Cost Accountants in CS Act and CWA Act respectively.)
Volume II of Code of Ethics issued by ICAI states that in discharging his professional responsibilities it is expected that a Chartered Accountant would exercise a reasonable degree of diligence in his professional assignment. This would imply that a member in practice keeps himself updated of the changes and developments in the professional space that could have an impact on his professional assignments. The membershouldalsoactdiligentlyinaccordancewithapplicabletechnicaland professionalstandards.
It is stated that standards drafted by ICAI are not applicable for other professionals but one can take the advantage of the reading of those standards.
1. WHETHER STANDARDS ON AUDITING CAN BE APPLIED ON COMPILATION ENGAGEMENT PERFORMED BY PROFESSIONAL FOR GSTR-9/9A AND/OR GSTR-9C HERE?
It is not required to perform attestation services on compilation engagement performed by professional for GSTR-9/9A and/or GSTR-9C and therefore it is clear that this assignment does not require to provide any assurance services. In the opinion of authors, neither Standards on Auditing (SA) nor the Standards on Review Engagements (SRE) can be applied in the situation where the entity requests the CA to prepare the GSTR-9/9A and/or GSTR-9C. (Conclusion does not end here so read the text written in next para)
2. THEN WHICH TECHNICAL STANDARD SHOULD BE APPLIED FOR PERFORMING THE ASSIGNMENT OF PREPARATION OF GSTR-9/9A AND/OR GSTR-9C?
In the opinion of authors, SRS-4410 i.e. Compilation Engagement should be referred which prescribes the set of procedures and responsibility of management and professional.
Meaning of compilation engagement?
As per Para 17 of SRS-4410, Compilation engagement means an engagement in which a practitioner applies accounting and financial reporting expertise to assist management in the preparation and presentation of financialinformationofanentity in accordance with anapplicablefinancialreportingframework(definedbelow), and reports as required by this SRS.
Applicable financial reporting framework means the financial reporting framework adopted by management and, where appropriate, those charged with governance in the preparation of the financial information that is acceptable in view of the nature of the entity and the objective of the financial information,orthatisrequiredbylaw orregulation. (Ref: Para A29–A31)
Preparation of GSTR-9/9A and/or GSTR-9C is satisfying the conditions of the definition of ‘Compilation Engagement’ because:
(a) Preparation of GSTR-9/9A and/or GSTR-9C an engagement in which a practitioner
preparation and presentation of
(b) GSTR-9/9A and/or GSTR-9C , being requirement of the law is anapplicable
3. RESPONSIBILITY OF PROFESSIONAL FOR COMPILATION ENGAGEMENT
Professional shall take responsibility for:
(a) The overall quality of each compilation engagement to which he is assigned; and
(b policies and procedures:
(
i) appropriate procedures regarding the acceptance and continuance of client relationships and engagements;
(ii competence and capabilities to perform the compilation engagement;
(
iii) Being alert for indications of non-compliance by members of the engagement team with relevant ethical requirements, and determining the appropriate action if matters come to the professional’s attention indicating that members of the engagement team have not complied with relevant ethical requirements;
(
iv) Directing, supervising and performing the engagement in compliance with professional standards and applicable legal and regulatory requirements; and
(
v) Taking responsibility for appropriate engagement documentation being maintained.
4. AGREEING TO THE TERMS OF APPOINTMENT
Under this SRS, the practitioner is required to obtain the agreement of management, or where applicable those charged with governance, on management’s responsibilities in relation to both the financial information and the compilation engagement as a condition precedent to accepting the engagement.
In smaller entities, management, or those charged with governance where applicable, may not be well-informed about what those responsibilities are, including those arising in applicable law or regulation. In order to obtain management’s agreement on an informed basis, the practitioner may find it necessary to discuss those responsibilities with management in advance of seeking management’s agreement on its responsibilities. If management does not acknowledge its responsibilities in the context of a compilation engagement, that the practitioner is not able to undertake the engagement, and it is not appropriate for the practitioner to accept the engagement unless required to do so under applicable law or regulation. In circumstances where the practitioner is nevertheless required to accept the engagement, the practitioner may need to communicate with management about the importance of these matters and the implications for the engagement.
5. RESPONSIBILITY OF MANAGEMENT
The compilation engagement to be performed is conducted on the basis that you acknowledge and understand that our role is to assist you in the preparation and presentation of the financial statements in accordance with the financial reporting framework you have adopted for the financial statements. Accordingly, you have the following overall
responsibilities that are fundamental to our undertaking the compilation engagement in accordance with SRS 4410 (Revised):
(a
(
b) Responsibility for the design, implementation and maintenance of such internal statements that are free from material misstatement, whether due to fraud or error.
(
c) Responsibility for the accuracy and completeness of the records, documents, explanations and other information you provide to us for the purpose of compiling
(
d) Responsibility for the judgments needed in the preparation and presentation of in the course of the compilation engagement.
6. RELIANCE TO BE PLACED BY THE PRACTITIONER
The practitioner is entitled to rely on management to provide all relevant information for the compilation engagement on an accurate, complete and timely basis. The form of the information provided by management for the purpose of the engagement will vary in different engagement circumstances. In broad terms, it will comprise records, documents, explanations and other information relevant to the compilation of the financial information using the applicable financial reporting framework. The information provided may include, for example, information about management assumptions, intentions or plans underlying development of accounting estimates needed to compile the information under the applicable financial reporting framework.
7. KEY FACTORS TO BE INCORPORATED IN THE REPORT TO BE ISSUED BY PRACTITIONER
Financial information prepared for a special purpose, i.e. reporting requirements established by a regulator, in accordance with provisions information.
Distribution of the practitioner’s report is restricted to the intended users.
8. FORMAT OF COMPILATION REPORT
[To the Management of ABC Company]
We have compiled the accompanying schedule of [identify the compiled financial information] of ABC Company as at March 31, 20XX (“the Schedule”) based on information you have provided.
We performed this compilation engagement in accordance with Standard on Related Services 4410 (Revised), Compilation Engagements.
We have applied our expertise in accounting and financial reporting to assist you in the preparation and presentation of the Schedule as prescribed by [insert name of or reference to the relevant regulation]. We have complied with relevant ethical requirements.
This Schedule and the accuracy and completeness of the information used to compile it are your responsibility.
Since a compilation engagement is not an assurance engagement, we are not required to verify the accuracy or completeness of the information you provided to us to compile the Schedule. Accordingly, we do not express an audit opinion or a review conclusion on whether the Schedule is prepared in accordance with [insert name of or reference to applicable financial reporting framework as specified in the relevant regulation].
As stated in Note X, the Schedule is prepared and presented on the basis prescribed by [insert name of or reference to the applicable financial reporting framework as specified in the relevant regulation], for the purpose of ABC Company’s compliance with [insert name of or reference to the relevant regulation] Accordingly, the Schedule is for use only in connection with that purpose and may not be suitable for any other purpose.
Our compilation report is intended solely for the use of ABC Company and Regulator F, and should not be distributed to parties other than ABC Company or Regulator F.
For XYZ and Co.
Chartered Accountants
Firm’s Registration Number
Signature
(Name of the Member Signing the Compilation Report)
GST Annual Return & Reconciliation is a comprehensive yet practical reference to understanding and implementing the Annual Return (GSTR-9) and Reconciliation Statement (GSTR-9C) under India’s GST law. Updated with all amendments as per Notification No. 13/2025-CT dated 17th September 2025, this Edition integrates law, accounting, audit, and procedural practice, enabling professionals and businesses to ensure accuracy, compliance, and audit preparedness in their annual filings. Authored by seasoned experts, the book offers a 360° approach to GST finalisation, combining legal interpretation, analytical insights, and practical tools that seamlessly connect financial statements with GST disclosures. This book is an essential resource for:
• Chartered Accountants, Cost Accountants, Company Secretaries, and GST Practitioners
The Present Publication is the 8th Edition | 2026, authored by Adv. Vivek Laddha, Dr Shailendra Saxena, and CA. Pooja Patwari, with the following noteworthy features:
• [Covers Latest Amendments] Incorporates revised formats and instructions for GSTR-9 & 9C (FY 2024–25)
• [Practical Focus] Features 30+ case studies and 50+ FAQs addressing reconciliation errors and ITC mismatches
• [Pre-filing Tools] Includes checklists for documentation, supply validation, and internal audit review
• [Financial Alignment] Explains the mapping of financial statement items to GST returns with AS/Ind AS linkage
• [Authoritative References] Includes key circulars, clarifications, and implications of Rule 37A
• [Structured Filing Approach] Provides step-by-step walkthroughs of GSTR-9 & 9C with examples and tables
• [Professional Resources] Contains model engagement letters, compilation reports, and FAQs issued by GSTN
