The Goods and Services Tax (GST) annual return filing has always been one of the most demanding compliance exercises for taxpayers and professionals. For FY 2024–25, the compliance burden has increased substantially due to wide-ranging amendments introduced in FORM GSTR-9 (Annual Return) and FORM GSTR-9C (Reconciliation Statement).

Recognising the gravity of these changes, the Bombay Chartered Accountants’ Society (BCAS), in its representation dated 11 December 2025, has requested the government to grant at least a three-month extension for filing GST annual returns. BCAS has stated that this extension is essential to allow taxpayers and professionals sufficient time to understand the amendments, ensure data accuracy, upgrade systems, and complete compliance responsibly.

Background: Why the Deadline Extension Has Been Sought

As per GST law, taxpayers are required to file GSTR-9 and GSTR-9C by 31 December following the end of the financial year. These returns consolidate monthly filings and reconcile them with audited financial statements.

However, for FY 2024–25, the annual return framework has undergone fundamental policy-level changes, notified primarily through Notifications 12/2024-CT and 13/2025-CT. According to BCAS, these are not incremental changes but a reversal of long-standing practical relaxations that businesses and professionals had relied upon for years.

The cumulative impact of these changes has created severe compliance pressure across the ecosystem.

Cumulative Impact and the Case for Extension

BCAS has highlighted that the combined effect of procedural, technical, and system-level changes has significantly strained taxpayers and professionals. The key concerns are outlined below.

1. Procedural Squeeze on Preparation Time

For FY 2024–25, FORM GSTR-9 can be filed only after all GSTR-1 and GSTR-3B returns for the year are submitted. Any delay in monthly returns directly blocks annual return filing.

This creates a domino effect, drastically reducing the effective time available for preparing annual returns that are now far more complex than before.

2. Substantial Increase in Compliance Effort

The shift from optional and consolidated reporting to mandatory, granular disclosures across multiple tables in GSTR-9 and GSTR-9C requires a complete overhaul of data collation and reconciliation processes.

Taxpayers must now perform detailed transaction-level analysis instead of relying on summary-level reporting, significantly increasing time, effort, and professional costs.

3. Heightened Risk of Inadvertent Errors

With new reconciliation formulas and nuanced disclosures, the risk of unintentional errors has increased sharply. For example, incorrect application of the new Net ITC formula, or misclassification of reclaimed ITC under Rule 37 or Rule 37A, can lead to incorrect tax liability declarations.

Such errors expose even compliant taxpayers to scrutiny, notices, interest, penalties, and litigation, despite the absence of any intent to evade tax.

4. Need for System and Process Upgrades

To comply accurately, taxpayers and consultants require adequate time to:

1. Understand the amended provisions
2. Train internal teams
3. Upgrade accounting software and ERP systems
4. Modify internal controls and data-tracking mechanisms

Without a reasonable transition period, compliance becomes error-prone and inefficient.

Escalating Complexity of GST Annual Compliance

BCAS has pointed out that GSTR-9 and GSTR-9C are not static forms. Over the years, they have been amended repeatedly through multiple notifications, including 74/2018-CT, 56/2019-CT, 79/2020-CT, 38/2023-CT, and most recently 12/2024-CT and 13/2025-CT.

While these changes aim to refine GST reporting, continuous evolution creates a moving compliance target, forcing professionals to constantly adapt systems and reconciliation logic.

Key Challenges in Filing GSTR-9 for FY 2024–25

Increased Granularity in ITC Reporting

Recent amendments have significantly altered ITC reporting requirements, including:

1. Introduction of Table 6A(1) for prior-year ITC availed in the current year
2. Mandatory rule-wise break-up of ITC reversals in Table 7
3. Separate reporting of ITC availed, reversed, and reclaimed
4. New reporting of IGST on imports availed in subsequent years

These changes require new data trackers, retrospective analysis, and transaction-level mapping that many systems were never designed to capture.

Revised Auto-Population Logic of Table 8A

The basis for auto-populating Table 8A has changed multiple times—from GSTR-2A to GSTR-2B, and now back to document-date-based reporting.

This forces taxpayers to perform fresh year-wise ITC reconciliation for each GSTIN, filtering out prior-year invoices and addressing mismatches that were earlier system-generated.

Additionally, taxpayers are reporting technical glitches on the GST portal, including auto-populated figures appearing as Nil even after filing.

Complex Reporting of Spillover Transactions

Mandatory reporting of ITC availed or reversed in subsequent years (Tables 12, 13, 8C) requires careful segregation to avoid reconciliation mismatches. Any misclassification here can trigger scrutiny under Table 8D, one of the key audit red flags.

Break in Net ITC Reconciliation Logic

From FY 2024–25 onwards, Net ITC in GSTR-3B no longer directly reconciles with Net ITC in GSTR-9. A new reconciliation formula has been introduced, requiring complete re-engineering of long-used reconciliation workbooks.

This also creates mismatches in GSTR-9C Table 12, where ITC as per books may not align with ITC reported in returns, even when compliance is correct.

Challenges in Preparing GSTR-9C

Increased Turnover Reconciliation Complexity

Earlier, multiple turnover adjustments could be reported in a consolidated manner. This relaxation has been withdrawn. Taxpayers must now report each adjustment separately across multiple tables, requiring deep mapping between audited financials and GST data.

Mandatory Cross-Year ITC Reconciliation

Tables 12B and 12C now require mandatory reporting of ITC booked and availed across different financial years. Reconciling accrual-based accounting with GST-based availment timelines significantly increases analytical effort.

Other Practical Constraints

1. FAQs clarifying these changes have been issued late in the compliance cycle, increasing interpretational uncertainty
2. GSTR-9C is dependent on audited financial statements, which often become available only after November due to extended audit deadlines
3. Annual returns must be filed separately for each GST registration, multiplying the workload for multi-state businesses

Why This Issue Matters for Taxpayers and Accountants

GST Annual Returns Are a Compliance Foundation

Annual returns form the basis for audits, assessments, and departmental scrutiny. Errors at this stage have long-term consequences.

Higher Risk of Penalties and Litigation

Compressed timelines increase the likelihood of genuine mistakes, leading to interest, penalties, and avoidable disputes.

Severe Pressure on Professionals

Frequent changes combined with limited time compromise quality checks, increasing professional and reputational risk.

Need for Sustainable Compliance

An extension would promote accurate, transparent, and sustainable compliance rather than rushed filings.

Conclusion: A Practical and Justified Demand

The request by BCAS for extending the GST annual return deadline is reasonable, pragmatic, and taxpayer-centric. The scale of amendments introduced for FY 2024–25 necessitates a transition period to ensure accuracy and reduce litigation.

Granting the requested extension would strengthen trust between taxpayers and the administration, improve compliance quality, and support the long-term objectives of the GST regime.