GSTR-9: Who Must File, and Who Is Exempt

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 seven years the small-taxpayer exemption was granted one financial year at a time, by a fresh notification each December. Notification No. 15/2025-CT dated 17 September 2025 ended that — the ₹2 crore exemption now runs from FY 2024-25 onwards without renewal.

Section 44 requires "Every registered person, other than an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person" to furnish an annual return. A second proviso excludes "any department of the Central Government or a State Government or a local authority, whose books of account are subject to audit by the Comptroller and Auditor-General of India" or a local-authority auditor. Rule 80(1) prescribes Form GSTR-9, due 31 December following the financial year; GSTR-9A for composition taxpayers and GSTR-9B for e-commerce operators collecting TCS.

The five statutory exclusions

These are exclusions by status, not by turnover. An ISD with ₹500 crore of distributed credit files no GSTR-9; a regular taxpayer with ₹3 crore of turnover does.

The turnover exemption, and how it became permanent

Section 44 also empowers the Commissioner, on the Council's recommendation, to "exempt any class of registered persons from filing annual return."

The history is a sequence of one-year notifications. Notifications No. 47/2019-CT dated 09.10.2019 and 77/2020-CT dated 15.10.2020 made filing optional for taxpayers with aggregate turnover up to ₹2 crore for FY 2017-18, 2018-19 and 2019-20. For FY 2020-21, 2021-22, 2022-23 (Notification No. 32/2023-CT) and 2023-24 (Notification No. 14/2024-CT), the same relief was extended year by year.

Then it was made standing. "Vide Notification No. 15/2025-CT dated 17.09.2025, registered persons with aggregate turnover upto ₹2 crores in any financial year have been exempted from filing Annual Return under Section 44(1) for that financial year, from Financial Year 2024-25 onwards."

Two things follow. No further annual notification is needed, and the test is applied year by year — a taxpayer at ₹1.8 crore this year and ₹2.4 crore next year is exempt for the first and liable for the second.

And note the phrasing of the earlier relief. It made filing optional, not prohibited. A taxpayer below the threshold who chooses to file is filing a valid return.

Four situations that catch people out

Nil return for an idle GSTIN. "A person having multiple registrations under GST and whose aggregate turnover in the financial year is more than two crore rupees should also file a Nil Annual Return for those GSTIN which do not have any transactions during the year."

The reason is that aggregate turnover is a PAN-level figure. Once the PAN crosses ₹2 crore, every GSTIN under it is outside the exemption — including a registration that did nothing all year.

Cancelled registration. "A person whose registration has been cancelled during the year is also required to file the Annual return unless the final return has been filed and cancellation is completed before 31st March of the relevant financial year."

So mid-year cancellation does not end the obligation unless the whole process, including GSTR-10, completed before the year did.

Opting in or out of composition. "A registered person who has opted in or opted out of composition is required to file both Form GSTR-9 & GSTR-9A for the relevant period."

Two returns for one financial year, each covering the part of the year under the respective scheme.

No revision. "Form GSTR-9 does not allow for any revision after filing."

What filing the return commits you to

The Guide is direct about the weight of the document:

"The declaration of the information in the Annual returns has multiple implications. Being a statutory document under GST Law, furnishing of any false information in any return is an offence which may attract penalty… Further, the information in the Annual Return can be relied upon by the tax authorities at the time of scrutiny, and any deviation or non-compliance may lead to initiation of proceedings."

And it is the final self-correction opportunity. "annual return is the last chance for the registered person to rectify any of the particulars filed in their monthly / quarterly GST returns, since section 73 of the CGST Act provides a unique opportunity of self-correction" — allowing a registered person, before service of a notice, to "suo motu pay the amount of tax with interest, if any."

But the correction has limits. "no input tax credit can be reversed or availed through the annual return. If registered persons find themselves liable for reversing any input tax credit, they may do the same through Form GST DRC-03 separately."

And liability identified while filing "can be deposited with Government using Form GST DRC-03. However, the same can be paid by utilizing the amount available in GST Cash Ledger only." The primary data source question →

Part I, and what the form actually is

GSTR-9 has six parts and nineteen tables:

Part I is auto-populated except the financial year, chosen from a drop-down. "'financial year' shall mean the year commencing on 1st day of April and closing on 31st day of March" under the General Clauses Act, the GST laws not defining it.

Legal name and trade name should be "verified by examining the certificate of registration issued by the tax department in Form GST REG-06." The Guide draws the distinction usefully: for a proprietary concern "the legal name will be that of the natural person say, Ramesh and the trade name will be, say, Classic Foods" — and a supply from the business stock or fixed assets is taxable, while selling "his old furniture / TV in his home which is in his name it will not be subject to tax; since it is not a business asset (personal effects)."

Three fields are auto-populated and non-editable: Table 6A (total ITC availed, sum of Table 4A of GSTR-3B), Table 8A (ITC as per GSTR-2B Table 3), and Table 9 (tax paid through cash and ITC). Everything else the portal computes is editable, which "allows the registered person to enter the actual value of supplies, tax paid, etc., as per books of accounts."

Key takeaways

• Section 44 excludes ISDs, section 51 and 52 taxpayers, casual taxable persons, non-resident taxable persons, and C&AG-audited government departments and local authorities.
• Rule 80: GSTR-9 by 31 December; GSTR-9A for composition; GSTR-9B for TCS-collecting e-commerce operators.
• Notification No. 15/2025-CT dated 17.09.2025 made the ₹2 crore exemption permanent from FY 2024-25 onwards — no annual renewal.
• A PAN above ₹2 crore must file a Nil return for every idle GSTIN under it.
• Cancellation mid-year does not remove the obligation unless the final return and cancellation completed before 31 March.
• Opting in or out of composition means filing both GSTR-9 and GSTR-9A for the respective periods.
• The return cannot be revised, and no ITC can be availed or reversed through it — use DRC-03, payable in cash only.
• Tables 6A, 8A and 9 are non-editable; the rest of the system-computed figures can be corrected to the books.

Read next

• GSTR-9: Late Fee Slabs and the Three-Year Bar
• GSTR-9: Primary Data Source — GSTR-1, GSTR-3B or Books?
• GSTR-9 Table 4: Outward Supplies on Which Tax Is Payable

Disclaimer: Positions stated as on 5 September 2026, based on sections 35, 44, 46, 47 and 73 of the CGST Act, 2017, rules 56 and 80 of the CGST Rules, 2017, and Notifications No. 47/2019, 77/2020, 32/2023, 14/2024 and 15/2025-Central Tax, as reproduced in the ICAI Technical Guide on GST Annual Return (Form GSTR-9).