BCAS Urges GST Council To Extend GSTR-9, GSTR-9C Due Dates For FY 2024–25

The due date for filing Form GSTR-9 for a particular financial year is 31st December of subsequent financial year

The Bombay Chartered Accountants Society (BCAS) has submitted a representation to the GST Council, flagging serious practical and technical challenges faced by taxpayers and tax professionals in filing the Annual Return (FORM GSTR-9) and Reconciliation Statement (FORM GSTR-9C) for FY 2024–25.

BCAS has also urged the Council to grant a reasonable extension of the due date for filing the two forms, citing increased complexity and compliance burden following recent amendments.

In its representation, BCAS pointed out that extensive changes have been introduced in FORM GSTR-9 and FORM GSTR-9C through Notification No. 12/2024-CT and 13/2025-CT, significantly altering disclosure requirements and reconciliation processes.

According to the body, these amendments have led to a sharp rise in compliance difficulties, especially for professionals handling annual GST filings at scale.

GSTR-9 is the annual return summarising all GST transactions for a financial year, while GSTR-9C is the reconciliation statement matching GST returns with audited financial statements.

The due date for filing Form GSTR-9 and GSTR-9C for a particular financial year is 31st December of subsequent financial year.

Issues Flag By BCAS:

1. The escalating complexity of the annual compliance framework

With the continuous efforts to refine the GST framework, the annual compliance forms, GSTR-9 and GSTR-9C, have been subject to numerous amendments by a series of notifications issued over the years.

BCAS argued that this constant evolution, while aimed at improvement, creates a moving target for compliance.

“It demands that taxpayers and professionals perpetually adapt their data management systems, reconciliation processes, and reporting software,” it added.

2. Critical challenges in filing FORM GSTR-9 of FY 2024-25

While the annual return is intended to consolidate the monthly or quarterly filings, the recent amendments represent a fundamental policy shift, BCAS stated, adding that this reversal of accepted practice, rather than an incremental change, is the primary driver of the current compliance strain, necessitating intricate data segregation, meticulous tracking of cross-periop transactions, and the application of new reconciliation logic.

Increased Granularity and Intricacy in ITC Reporting, complications from new auto-population logic in Table 8, reporting of spillover transactions and the discrepancy between Net ITC as per GSTR-3B and GSTR-9 are highlighted as major issues.

3. Significant hurdles in preparing FORM GSTR-9с

FORM GSTR-9C is intended to bridge the gap between GST returns and audited financial statements. However, the recent withdrawal of long-standing practical relaxations has made this reconciliation significantly more arduous and demanding.

Increased Complexity in Turnover Reconciliation, and mandatory Reporting of Cross-Year ITC Reconciliation are major challenges.

4. Clarification challenges

When significant changes are introduced late in the compliance cycle, subsequent clarifications, even those issued in rapid succession, add to the administrative burden and lead to delays as professionals and taxpayers must first absorb the new legal provisions and then interpret the clarification, BCAS added.

5. Dependency on Audited Annual Financial Statements

The process of filing GSTR-9C is fundamentally dependent on the completion and availability of the audited annual financial statements. The reconciliation statement (FORM GSTR-9C) requires reconciling the turnover declared in the Annual Return (GSTR-9) with the turnover reported in the audited annual financial statements.

The preparation of GSTR-9C mandates the successful completion of other statutory audits, including the submission of the audited annual accounts. With the extension of tax audit due dates from 30th September to 10th November, the data for preparing GSTR-9/9C became available only after mid-November in many cases. This has significantly compressed the timeline available for GSTR9/9C.

6. Wider Compliance Scope and Workload

The annual returns are to be filed for each registration obtained under GST. Therefore, if a taxpayer is registered in multiple states, separate compliance needs to be done for each such registration which

substantially increases the scope of compliance and workload.

7. Cumulative Impact and the Case for an Extension

The combined effect of these numerous, intricate changes imposes a significant strain on the resources of taxpayers and professionals, thereby compelling a case for an extension of the filing deadline.

These amendments represent a fundamental policy shift, moving away from practical relaxations that the industry had built processes around for several years. This reversal of accepted practice, rather than an

incremental change, is the primary driver of the current compliance strain.

In view of the challenges, BCAS has requested the GST Council to consider granting a reasonable extension of the due date for filing FORM GSTR-9 and GSTR-9C for FY 2024–25. The society said additional time would help ensure accurate compliance, reduce errors, and avoid unnecessary disputes or penalties.