GSTR-9 Part VI: Tables 15 to 19, Demands, Refunds and HSN

GSTR explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

Part VI is where the optional tables live — except that Table 17 stopped being optional in FY 2021-22. And at the end of it sits a verification clause that asks the signatory to affirm something most people never read: that the benefit of any reduction in output tax has been passed on.

Table 15 reports refunds and demands; Table 16 covers supplies from composition taxpayers, deemed supply under section 143, and goods sent on approval but not returned; Table 17 and Table 18 are the HSN-wise summaries of outward and inward supplies; Table 19 is late fee payable and paid. Tables 15 and 16 have been optional throughout; Table 17 became mandatory from FY 2021-22, with Table 18 remaining optional for FY 2021-22, 2022-23 and 2023-24.

Table 15: refunds and demands

Seven rows — total refund claimed, sanctioned, rejected, pending, total demand of taxes, taxes paid in respect of it, and demands pending.

What goes into "claimed" — the aggregate of refund claims "which have been sanctioned, rejected or pending for processing", covering excess tax paid; cash ledger balance; unutilised ITC on zero-rated supplies without payment; tax paid on zero-rated supplies with payment; additional IGST on upward price revision after export; deemed exports, by supplier or by recipient; SEZ supplies; inverted duty structure; pre-deposit; intra-State treated as inter-State and vice versa; and provisional refunds received.

"Non-GST refund claims (i.e. refund claimed under erstwhile law) should not be reported here."

And for export refunds, rule 96(1) governs when a claim exists at all: "shipping bill filed by an exporter of goods shall be deemed to be an application for refund only when export general manifest (EGM)… is furnished by person-in-charge of conveyance and a valid Form GSTR-3B is furnished."

Three reporting rules worth holding:

• Sanctioned includes refund "granted and adjusted against any outstanding demand of taxes in Form GST RFD-07… before the adjustment", and "even the provisional refund (of 90%) sanctioned must be reported" under rule 91(2) and RFD-04;
• Rejected excludes cases "where deficiency memo has been issued but order whether sanctioned or rejected has not been issued";
• Pending covers claims "for which acknowledgment has been received… excluding the provisional refunds received."

Demands are reported "for which an order confirming the demand has been issued by the adjudicating authority" — so a show cause notice is not a demand for this purpose.

Table 16: three deemed-supply traps

16A — supplies received from composition taxpayers. "Composition taxpayers cannot issue tax invoice; they must issue a bill of supply as mentioned in section 31(3)(c)." Only inward supply from a composition taxpayer goes here — "Any inward supplies which are nil-rated, exempted, non-GST etc. should not be a part of this."

16B — deemed supply under section 143. "if inputs sent for job work are not received by the principal within 1 year… the same would be deemed as supply in the hands of the principal on the day on which the inputs were sent." For capital goods (other than moulds and dies, jigs and fixtures, or tools), the period is 3 years.

The deeming is retrospective to the date of dispatch, which is what generates interest. "Every registered person has to maintain job work register which will be the source for filing the Form GST ITC-04."

16C — goods sent on approval but not returned. "if goods sent on approval are not returned by the recipient to the supplier within 6 months from the date of removal, the same shall be treated as supply in the hands of the supplier."

And the reason this is genuinely hard to detect: "Since no actual sales happened when goods were sent… this transaction would not be reported in any return till the permissible time limit expires as given in section 31(7); such goods are sent on delivery challan only. Therefore, there would be no track to capture such a transaction."

The Guide's suggested route: "verify closing stock in the books of account in which goods sent on approval basis can be scrutinized… to identify goods sent 6 months back but not returned or accepted… Tax invoice is required to be raised and tax needs to be paid."

Tables 17 and 18: the HSN summaries

Table 17 is no longer optional. "registered persons have an option not to report the information… in Table no. 17 and 18 for the FY 2017-18, 2018-19, 2019-20 & 2020-21. However, for FY 2021-22, 2022-23 and 2023-24 option is only for Table 18."

The digit requirement, from Notification No. 14/2022-CT dated 05.07.2022: "six digits level for the taxpayers having annual turnover in the preceding year above ₹5 cr and at four digits level for all B2B supplies for taxpayers having annual turnover in the preceding year upto ₹5 Cr."

The invoice-level rule that precedes it, from Notification No. 78/2020-CT dated 15.10.2020 effective 01.04.2021: four digits up to ₹5 crore, six digits above. Before that, HSN was optional up to ₹1.5 crore, two digits between ₹1.5 and ₹5 crore, and four digits above ₹5 crore.

Five columns to get right:

• HSN code — "ought to be corroborated with allied documents such as E-way bills, delivery challans, notifications and clarifications including explanatory notes", and "tax rates may have been changed during the financial year… this column should be so filled that it reflects or captures such rate changes";
• UQC — "the code of measurement of a particular commodity i.e. Kilograms, Meters, Litres, Numbers";
• Total quantity — "every registered person would have to maintain complete quantitative records";
• Taxable value — "not defined under the Act; it must be understood to be the value of taxable supply on which tax becomes payable";
• Rate of tax — "When there is a change, there will be separate details for each rate of tax in respect of the same supply."

And the cross-check: "Caution must be exercised to ensure that such HSN based taxable supplies reflected in this table match with turnover reflected elsewhere in the Annual Return."

The classification framework is the Customs one — "the rules for the interpretation of the First Schedule to the Customs Tariff Act, 1975 including the section and chapter notes and the general explanatory notes… shall, so far as may be, apply to the interpretation of the notification issued under the GST Laws." HSN has 21 sections, 99 chapters, 1,244 headings and 5,244 sub-headings, with Chapter 99 used for services. Classification and the GRI →

The verification clause

"I hereby solemnly affirm and declare that the information given herein above is true and correct to the best of my knowledge and belief and nothing has been concealed there from and in case of any reduction in output tax liability the benefit thereof has been / will be passed on to the recipient of supply."

On "conceal", the Guide cites Dilip N. Shroff v. Joint Commissioner of Income Tax [2007 (219) ELT 15 (SC)]: "to hide or keep secret… to prevent the discovery of; to withhold knowledge of. The offence of concealment is, thus, a direct attempt to hide an item of income."

And the distinction the Court drew: *"'Concealment of income' and 'furnishing of inaccurate particulars' are different. Both… refer to deliberate acts… A mere omission or negligence would not constitute a deliberate act of suppressio veri or suggestio falsi."*

The Guide's conclusion: "malafide or dolus malus becomes a pre-requisite to prove an act of concealment… it is reiterated that mere failure to provide information or providing inaccurate information also would not amount to concealment."

The second limb is the one that gets overlooked. It engages section 171 — anti-profiteering — under which "any benefit accruing to a Registered Person ought to be passed on to the recipient by way of commensurate reduction in prices", whether from a rate reduction or additional input tax credit. "the Registered Person is cast with the onerous responsibility of finding out whether any such benefit has accrued to him."

Signing the return is therefore an affirmation on section 171 compliance, not merely on the accuracy of the tables above it.

Key takeaways

• Table 15 reports refunds claimed, sanctioned, rejected and pending and demands confirmed, paid and pending; erstwhile-law refunds are excluded; provisional 90% refunds are reported; deficiency-memo cases are not "rejected".
• Table 16 captures composition purchases, section 143 deemed supplies (1 year for inputs, 3 years for capital goods other than moulds, dies, jigs, fixtures and tools) and goods on approval not returned in 6 months.
• Approval-basis supplies leave no return trail — they move on delivery challan, so closing stock must be scrutinised.
• Table 17 became mandatory from FY 2021-22; Table 18 remained optional through FY 2023-24.
• Six-digit HSN above ₹5 crore, four-digit for all B2B supplies up to ₹5 crore — Notification No. 14/2022-CT.
• Rate changes during the year require separate lines for the same HSN, and HSN turnover must tie to the rest of the return.
• The verification clause requires affirmation on concealment — which, per Dilip N. Shroff, needs mala fides, not mere omission.
• Its second limb engages section 171, making the signatory affirm that any rate or credit benefit was passed on.

Read next

• GSTR-9 Part V: Tables 10 to 14, the Next-Year Corrections
• GSTR-9: Late Fee Slabs and the Three-Year Bar
• GSTR-9 Table 9: Tax Payable Against Tax Paid

Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9 and its instructions, sections 31(3)(c), 31(7), 143 and 171 of the CGST Act, 2017, rules 46(g), 91(2) and 96(1) of the CGST Rules, 2017, Notifications No. 78/2020 and 14/2022-Central Tax, the Customs Tariff Act, 1975 and the decision in Dilip N. Shroff v. Joint Commissioner of Income Tax, as reproduced in the ICAI Technical Guide on GST Annual Return (Form GSTR-9).