📝 Introduction

As the filing season for GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) approaches for FY 2024-25, GSTN has released a supplementary FAQ document based on comments and queries received through various channels. These FAQs help taxpayers understand the correct reporting methodology for complex ITC situations, timing differences, earlier-year adjustments, and table-wise disclosures.

This article summarises these newly issued FAQs and explains their implications with relevant legal background for accurate and compliant reporting.

📚 Detailed Compilation of Additional FAQs (Issued on 04-12-2025)

1️⃣ Reporting RCM Paid in a Subsequent Financial Year

Query:

RCM tax pertaining to FY 2024-25 was paid in GSTR-3B of FY 2025-26. Should this liability and related ITC be reported in GSTR-9 of FY 2024-25 or 2025-26?

GSTN Clarification:

Both RCM liability and ITC must be reported in GSTR-9 of FY 2025-26.

Legal Basis:

CBIC Press Release dated 03 July 2019 clarified that RCM paid in a later year must be declared in the year of payment, not the year to which it pertains.

2️⃣ ITC of 2023-24 Claimed & Reversed in FY 2024-25 – How to Report?

Issue:

Taxpayer availed ITC of FY 2023-24 in FY 2024-25 (Table 4A5 of GSTR-3B) and reversed it in FY 2024-25 (Table 4B1). How should this be shown in GSTR-9 of FY 2024-25?

Clarification:

• ITC related to previous FY but availed in current FY must be reported in Table 6A1 of GSTR-9 (FY 2024-25).

• However, reversal of such ITC shall NOT be reported in Table 7.

Reason:

Table 6 & Table 7 capture current-year ITC only.

3️⃣ Table 12B of GSTR-9C Appears Redundant – What to Do?

Concern:

Table 12B of GSTR-9C (ITC booked earlier & claimed in current year) becomes redundant because Table 7J of GSTR-9 does not consider earlier-year ITC.

Clarification:

• Table 12B still needs to be reported.

• It will not appear in Table 12A or 12E.

• Any resulting mismatch in Table 12F should be explained in Table 13 (Reconciliation Remarks) of GSTR-9C.

4️⃣ Mismatch Between Table 4C of GSTR-3B and Table 7J of GSTR-9

Issue:

Table 4C of GSTR-3B may include ITC of earlier FY (2023-24) claimed or reversed in 2024-25, but Table 7J contains ITC pertaining only to FY 2024-25, causing mismatch.

Clarification:

GSTN confirms that such mismatch is expected and acceptable, as Table 7J captures current-year ITC only.

5️⃣ Reversal of ITC of 2023-24 in FY 2024-25 – Where to Report?

Clarification:

Such reversal should not be reported in GSTR-9 of FY 2024-25, because Table 7 captures reversals relating to current FY only.

6️⃣ Goods Received in Next FY, ITC Taken in Next FY – How to Reflect?

Issue:

• Goods pertain to FY 2023-24

• Received in April 2024

• ITC claimed in FY 2024-25

Clarification:

• ITC should be reported in Table 6A1 of GSTR-9 for FY 2024-25.

• Table 12B of GSTR-9C will depend on the accounting methodology adopted.

• If mismatch arises in Table 12F, the taxpayer should record reasons in Table 13.

7️⃣ Reporting Non-GST Purchases in GSTR-9

Clarification:

Non-GST purchases are not required to be reported in GSTR-9 as there is no dedicated table for such disclosure.

8️⃣ Who Must Report Table 4G1 of GSTR-9?

Clarification:

Table 4G1 is only for e-commerce operators liable to pay tax under Section 9(5) of the CGST Act.

🧭 Professional Insight

“The additional FAQs introduced by GSTN significantly streamline the reporting logic for annual returns. A clear distinction is now reinforced between current-year ITC and prior-period ITC, reducing ambiguity and ensuring cleaner reconciliations in GSTR-9 & GSTR-9C.”
— Tech-Tax Solutions

📑 Legal Framework Referenced

• Section 16, 17, 18 – CGST Act: ITC eligibility rules

• Section 37, 39 – CGST Act: Furnishing outward supplies & returns

• Rule 59 & 61 – CGST Rules: GSTR-1 and GSTR-3B

• Form GSTR-9 Instructions (Notified under Rule 80)

• Form GSTR-9C Instructions (Reconciliation Statement under Rule 80(3))

• CBIC Press Release dated 03-07-2019 (RCM disclosure principle)

🏁 Conclusion

The newly released FAQs provide much-needed clarification on ITC reporting, year-wise classification, reversals, treatment of earlier period ITC, and e-commerce reporting responsibilities. These explanations will help taxpayers file accurate, reconciled, and compliant GSTR-9 and GSTR-9C for FY 2024-25.

Taxpayers must ensure reconciliation between books, GSTR-3B, GSTR-2B, and GSTR-1 to avoid discrepancies and audit queries.