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.
For four financial years these rows were optional — credit notes could simply be netted against the supplies they related to. From FY 2021-22 that option was withdrawn, and every credit note, debit note and amendment on B2B, export, SEZ and deemed export supplies must now be reported on its own line.
Table 4I reports credit notes, 4J debit notes, 4K supplies or tax declared through amendments (+), and 4L supplies or tax reduced through amendments (−), all "in respect of transactions specified in (B) to (E) above" — B2B, exports on payment, SEZ on payment and deemed exports. 4M sub-totals I to L; 4N gives "Supplies and advances on which tax is to be paid (H + M)." "w.e.f. FY 2021-22, such option has been removed and netting of credit notes, debit notes, amendments are not allowed anymore."
When a credit note may be issued
Section 34(1) permits a credit note where one or more tax invoices have been issued and:
- "the taxable value or tax charged is found to exceed the taxable value or tax payable in respect of such supply";
- "the goods supplied are returned by the recipient";
- "the goods or services or both supplied are found to be deficient."
Only GST credit notes count. "Credit notes should be captured only if the suitable effect of GST is provided in them. Any commercial/accounting credit notes which do not contain the charge of GST should not be adjusted for the calculation of taxable value and tax amounts."
And only on taxable supplies. "Any supplies which are nil-rated, exempted, non-GST, etc., credit note in relation to such supplies should not be reported in this table" — those go to Table 5H.
The GSTR-1 reporting failure, and why it matters
This is the most substantive warning in the whole of Part II, and it concerns a practice that is common and looks harmless.
"The registered person should have reported the particulars of credit note in Form GSTR-1 (Table 9B). Failing to do so and only adjusting in GSTR-3B creates a data mismatch, allowing recipients to retain undue ITC without reversal. This practice will tantamount to unjust enrichment."
The mechanics: "If the credit note is not reported in GSTR-1 but only adjusted in GSTR-3B (e.g., by reducing the output tax payable in Table 3.1), the recipient's GSTR-2A/2B remains unchanged. As a result:"
- "The recipient continues to hold the full ITC without reversing the portion attributable to the credit note."
- "The supplier benefits from a reduced tax outflow in GSTR-3B, but the government's revenue is shortchanged because the ITC reversal doesn't occur."
- "Effectively, the recipient retains an 'unjust' tax credit that they are not entitled to, while the supplier avoids scrutiny on the mismatch until potentially flagged during reconciliation or audits."
And the closing assessment: "This scenario disrupts the seamless ITC chain, erodes trust in the self-assessed GST system."
The practical test is simple. Every credit note that reduced output tax in GSTR-3B should have a matching entry in Table 9B of GSTR-1. A count mismatch between the two is a reportable exposure, not a bookkeeping detail.
Where a credit note goes, by when it was adjusted
- Adjusted in the reporting FY in GSTR-3B → Table 4I;
- Adjusted in the next FY up to the specified date → Table 11;
- Not adjusted at all, because "there is no output tax liability against which credit note can be adjusted" → "apply for the refund under excess payment of tax through Form GST RFD-01 (with proper reason) as per Circular No. 137/07/2020-GST dated 13.04.2020."
One special case from the Press Release of 3 July 2019: "there may be situation where credit note has been issued in the next financial year related to the original supply reported in the reporting financial year, however the provision thereof has been made in the Books of Accounts in reporting financial year — then the same will be reported in Pt. V of Form GSTR-9 of the reporting financial year."
The specified date for credit notes comes from section 34(2) as amended by the Finance Act, 2022, notified w.e.f. 01.10.2022 by Notification No. 18/2022-CT: from FY 2021-22 onwards, the effect may be declared up to 30 November of the next FY or the date of furnishing the annual return, whichever is earlier. The specified date →
Evidencing the recipient's reversal
Because a supplier may reduce output tax only where the recipient reverses the corresponding credit, evidence is required.
Circular No. 212/6/2024-GST dated 26.06.2024 "has provided a clarification outlining a mechanism for obtaining suitable evidence of ITC reversal to ensure compliance with the conditions specified in Section 15(3)(b)(ii)":
- "A certificate issued by a Chartered Accountant (CA) or Cost Accountant (CMA) confirming the ITC reversal by the recipient";
- "However, if the total tax involved in discounts does not exceed ₹5,00,000 in a financial year, a self-declaration by the recipient will be enough."
The threshold is per recipient per financial year on the tax involved, not on the discount value — so a ₹5 lakh tax figure corresponds to a much larger discount at 18%.
The Guide also notes the older practical device: "The supplier should ask the receiver to issue him an accounting debit note as proof that he had reversed the ITC and the supplier is eligible for a reduction in outward tax liability."
Debit notes, and the interest they carry
Section 34(3) permits a debit note where "the taxable value or tax charged in that tax invoice is found to be less than the taxable value or tax payable."
Reporting is period-based: "A person issuing the debit note has to declare such details in the return for the month during which such debit note is issued. In the annual return, that person is required to disclose only those debit notes which pertain to the relevant financial year." A debit note of the previous FY reported and paid in the next FY up to the specified date goes to Tables 10 and 14.
And the sting: *"The time of supply for the debit note will be counted from the date of the original invoice date. Hence, in case of issuance of debit note, delayed payment of taxes has to be made good with payment of interest. This has been confirmed in the Central Excise regime by the Apex Court in Steel Authority of India Ltd v. Commissioner of Central Excise, Raipur [2019 (366) E.L.T. 369 (S.C.)]."*
So a debit note is not a fresh supply with a fresh time of supply. It corrects an under-declared original supply, and interest runs from that original date — which can be a substantial sum on a price revision raised a year later.
Credit note or amendment?
Section 39(9) allows rectification "if any registered person detects any omission or incorrect particulars other than as a result of scrutiny, audit, inspection or enforcement activity", in the return for the month of detection, subject to the same 30 November outer limit. Circular No. 26/26/2017-GST dated 29.12.2017 addresses the mechanics.
The Guide's decision tree is the cleanest statement of the difference:
| Situation | Action |
|---|---|
| Tax invoice issued, value is correct, but GSTR-1/3B filed with the wrong value | Amend or adjust in a subsequent GSTR-1/3B — Tables 4K and 4L |
| Tax invoice issued and the value itself is wrong | Issue a debit note or credit note — Tables 4I and 4J |
The distinction is between a wrong document and a wrong filing. If the invoice was right and the return was wrong, amend the return. If the invoice was wrong, issue a note. Amendment details come from Tables 9A and 9C of GSTR-1.
Key takeaways
- Netting off ended with FY 2020-21 — from FY 2021-22, credit notes, debit notes and amendments on rows B to E must be separately reported.
- Only GST credit and debit notes count; commercial notes without GST are excluded, as are notes on exempt, nil-rated and non-GST supplies.
- A credit note adjusted only in GSTR-3B and never reported in Table 9B of GSTR-1 leaves the recipient holding unreversed credit — described as unjust enrichment.
- Placement follows adjustment: reporting FY → 4I; next FY to the specified date → Table 11; no liability to adjust against → RFD-01 per Circular No. 137/07/2020.
- Circular No. 212/6/2024-GST: a CA or CMA certificate evidences the recipient's reversal, or a self-declaration where the tax on discounts is up to ₹5,00,000 in the year.
- A debit note takes the time of supply of the original invoice, so interest runs from that date — Steel Authority of India.
- Wrong return, right invoice → amend (4K/4L). Wrong invoice → credit or debit note (4I/4J).
Read next
- GSTR-9 Table 4: Outward Supplies on Which Tax Is Payable
- GSTR-9 Part V: Tables 10 to 14, the Next-Year Corrections
- GSTR-9 Table 5: Supplies on Which Tax Is Not Payable
Disclaimer: Positions stated as on 5 September 2026, based on sections 15(3), 34 and 39(9) of the CGST Act, 2017, Form GSTR-9, Notification No. 18/2022-Central Tax, Circulars No. 26/26/2017-GST, 137/07/2020-GST and 212/6/2024-GST, the CBIC Press Release dated 3 July 2019 and the decision in Steel Authority of India Ltd v. CCE, Raipur, as reproduced in the ICAI Technical Guide on GST Annual Return (Form GSTR-9).
Key Facts About GSTR
- Applies in: All states across India, under the relevant central law.
- Mode: Mostly online via the official government portal.
- Typical timeline: Ranges from a few days to a few weeks depending on the case.
- Non-compliance: May attract penalties, interest or late fees.
- Expert help: TaxClue completes the entire process end to end for you.
Can credit notes still be netted off in GSTR-9?
No. From FY 2021-22 onwards the netting option was withdrawn, and credit notes, debit notes and amendments must be reported separately in Tables 4I to 4L.
Are commercial credit notes reported in Table 4I?
No. Only credit notes carrying the charge of GST are reported; commercial or accounting notes without GST are excluded.
Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.
GSTR: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.