GST WEEKLY UPDATE :33/2025-26 (16.11.2025) By CA Vipul Khandhar

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-By CA Vipul Khandhar, Ahmedabad

Key Changes in GSTR-9 & GSTR-9C for FY 2024-25 (Compared to FY 2023-24)

These changes are based on CBIC notifications, GST portal updates, and official advisories.

Structural & Legal Changes

Threshold Exemption (Major Change)

Item	FY 2023-24	FY 2024-25
GSTR-9 Filing Exemption	Optional for turnover < ₹2 Crore (year-on-year based notification)	Permanent exemption for turnover < ₹2 Crore (Notification 15/2025-CT)
GSTR-9C Applicability	Turnover > ₹5 Crore	Same (no change)

ITC Reporting – Major Re-design

New Split of ITC Tables

Area	FY 2023-24	FY 2024-25
ITC Claimed Table	Table 6A (one consolidated figure)	Split into two: • Table 6A1 – Previous FY ITC claimed in current FY • Table 6A2 – Current FY eligible ITC
Reversal Reporting	Rule-wise breakup optional/limited	Mandatory rule-wise reporting: Rule 37, 37A, 38, 42, 43, Sec 17(5)
Deferred ITC	No separate reporting	Separate disclosure required (late-claimed ITC, imports ITC, etc.)

Auto-population Changes

Table 8A Auto Population

Item	FY 2023-24	FY 2024-25
Table 8A (ITC as per GSTR-2B)	Auto-populated but with limited validations	Now system-validated, stricter mismatch checks, more auto-population fields

This increases reconciliation accuracy but requires tighter monthly compliance.

Liability Reporting Changes

Liability Disclosure (Cash vs ITC)

Area	FY 2023-24	FY 2024-25
Tax paid break-up	Basic reporting	Split mandatory: • Paid through Cash • Paid through ITC
Late Fee Table	Not required separately	New rows added for late fee under Sec 47(2) for IGST/CGST/SGST

GSTR-9C Changes (Reconciliation Statement)

Area	FY 2023-24	FY 2024-25
Reporting Section 9(5)	Not mandatory separately	Now mandatory line item for supplies where liability falls on E-Commerce Operator
Tax Payable vs Tax Paid	Only “tax paid” shown	“Tax payable” must also be shown
Additional liability payment	Only cash allowed	Cash or ITC both allowed

GST Portal & System Controls

Area	FY 2023-24	FY 2024-25
Return Unlock Condition	Less strict	GSTR-9 & 9C can be filed only after all GSTR-1 & GSTR-3B are filed
Reconciliation Utility	Basic	Enhanced auto-validation and mismatch detection

Summary of Major Differences: (Quick View)

Category	What Changed in FY 2024-25
ITC Reporting	More detailed, new tables, strict rule-wise reversals
Liability Reporting	Split between ITC & Cash mandatory
GSTR-9C	Separate 9(5) reporting + tax payable disclosure
Additional Liability	Can be paid via ITC also
Table 8A	More strict matching with 2B
Exemption	< ₹2 crore turnover permanently exempt
Portal Controls	New validations, auto checks

2. Important Questions & Answers (FAQs):

Q1. What is the due date for filing GSTR-9 for FY 2024-25?

The due date is 31st December 2025 (as per normal rules).

Q2. Who is exempt from filing GSTR-9 for FY 2024-25?

Taxpayers with aggregate turnover below ₹2 crore are permanently exempt.

Q3. Who needs to file GSTR-9C for FY 2024-25?

Taxpayers with turnover above ₹5 crore.

Q4. I claimed ITC of FY 2023-24 in FY 2024-25. Where do I report?

Report it in Table 6A1 (New table).

Q5. Is rule-wise ITC reversal mandatory in FY 2024-25 GSTR-9?

Yes, mandatory for Rule 37, 37A, 38, 42, 43 and Sec-17(5).

Q6. Can additional tax liability discovered during GSTR-9C be paid using ITC?

Yes. For FY 2024-25, payment can be made through ITC or Cash.

Q7. How will late fees be reported in GSTR-9?

A new separate late fee table has been added for IGST, CGST, SGST/UTGST.

Q8. What are the new changes in Table 8A?

System-controlled auto-population from GSTR-2B with strict mismatch validation.

Q9. When can I file GSTR-9/9C?

Only after all GSTR-1 and GSTR-3B for FY 2024-25 are filed.

Q10. What is the biggest change in GSTR-9C?

Mandatory reporting of:
• Tax payable vs tax paid
• E-commerce liable supplies (Section 9(5))

AAR & Important Judgements:

(i) AAR On No ITC on GST Paid for Long-Term Land Lease Used for Factory Construction :

(Applicant – Agratas Energy Storage Solutions Pvt. Ltd.)

In yet another significant ruling reaffirming the restrictive scope of Section 17(5)(d) of the CGST Act, the Gujarat Authority for Advance Ruling (AAR) in Agratas Energy Storage Solutions Pvt Ltd held that Input Tax Credit (ITC) is not available on GST paid under reverse charge mechanism (RCM) on long-term land lease rentals taken for constructing an industrial facility—in this case, a large-scale car-battery cell manufacturing plant spread over 321 acres.

This ruling is crucial for industries engaged in large infrastructure/greenfield projects, renewable energy, EV manufacturing, industrial parks, and sectors where long-term land leasing is inherent.

The key question before the AAR was:

Whether ITC of GST paid on annual lease rentals for long-term land lease used for construction of a factory is available under the GST regime?

The AAR answered in the negative, invoking Section 17(5)(d).

The AAR concluded that the ITC is blocked, and its reasoning rests on five important legal propositions.

Section 17(5)(d) Bars ITC on Goods/Services Used “For Construction of Immovable Property”

The non-obstante clause in Section 17(5) overrides general ITC eligibility under Section 16.

The AAR observed:

Lease rentals were intrinsically linked to obtaining land for construction.
Land on which the factory would be constructed is the primary and indispensable input service for construction.
Therefore, the lease service is a supply used “for construction of immovable property”, squarely falling within Section 17(5)(d).

Supporting Precedents:

Case	Principle
Bayer Vapi Pvt Ltd (Guj. AAR)	ITC on land-lease premium blocked as it relates to immovable property construction.
GACL-NALCO Alkalies & Chemicals Pvt Ltd (Guj. AAR)	Long-term land lease for factory construction is ITC-ineligible.

(ii) Hon’ble Gujarat Highcourt Admits Challenge to 180-Day ITC Reversal Rule:

(Applicant – Priya Blue Industries Pvt. Ltd.)

The Gujarat High Court has issued notice to the Union Government and State GST authorities in a petition challenging the constitutional validity of the 2nd and 3rd provisos to Section 16(2) of the CGST Act — the provisions that mandate reversal of ITC with interest if payment to suppliers is not made within 180 days of the invoice.

Why the Challenge?

The petitioner, Priya Blue Industries Pvt. Ltd., argues that the 180-day rule:

Restricts commercial freedom by forcing businesses into rigid payment timelines
Penalises legitimate long credit cycles common in infrastructure, pharma, textiles, steel, manufacturing and trading
Causes working-capital strain and disrupts supply-chain financing
Creates cascading of taxes, contrary to GST’s core principle of seamless credit
Violates Articles 14 and 19(1)(g) by imposing unreasonable and arbitrary conditions on availing ITC

Under the challenged provisos, even when long payment terms are mutually agreed and contractually valid, ITC must be reversed if payment is not made within 180 days — despite the supplier having already paid GST to the Government.

What Happened in Court?

At the preliminary hearing, the highcourt has observed that the issues raised are substantial and merit detailed examination.

The Court therefore:

Issued notice to the Centre and State
Directed the Government to file a detailed response
Noted that the matter has significant implications for industry-wide working capital practices

The Revenue defended the provision’s intent but conceded that the challenge requires deeper scrutiny.

Disclaimer:

This publication contains information for general guidance only. It is not intended to address the circumstances of any particular individual or entity. Although the best of endeavour has been made to provide the provisions in a simpler and accurate form, there is no substitute to detailed research with regard to the specific situation of a particular individual or entity. We do not accept any responsibility for loss incurred by any person for acting or refraining to act as a result of any matter in this publication.