◆ CHECKLIST
GSTR-9 Annual Return
Reconciliation Checklist
Complete step-by-step checklist for filing your GSTR-9 Annual Return accurately — ITC reconciliation, GSTR-2B matching, RCM compliance, HSN summary, and auto-populated field verification. Updated for FY 2025-26.
📌 Important: GSTR-9 is due on 31 December following the close of each financial year. Late filing attracts ₹200/day penalty (₹100 CGST + ₹100 SGST), capped at 0.25% of turnover. Use this checklist to file on time and accurately.
Section 1: Pre-Filing Preparation
- ☐ Gather all GSTR-1 filed during the year — April to March (monthly/quarterly)
- ☐ Gather all GSTR-3B filed during the year — check if any amendments pending
- ☐ Download auto-populated GSTR-9 from GSTN portal — compare Table-wise with actual data
- ☐ Extract books of accounts summary — total turnover, taxable, exempt, nil-rated, non-GST
- ☐ Reconcile turnover (Table 5) — books vs GSTR-1 vs GSTR-3B; document any differences
- ☐ Check for amendments/credit notes — ensure reflected in GSTR-1 and books both
- ☐ Verify advance receipts — advances received and adjusted during the year (Table 4)
- ☐ Confirm cancelled/NIL-rated supplies — included under correct category
Section 2: Outward Supply Verification (Tables 4 & 5)
- ☐ Table 4 — Taxable outward supplies: Verify B2B, B2C, export, SEZ with GSTR-1 aggregate
- ☐ Table 5 — Exempt, nil-rated, non-GST supplies: Ensure all supply types classified correctly
- ☐ Reconcile with GSTR-3B (Table 3.1) — total outward taxable should match within tolerance
- ☐ Check exports (with/without payment) — LUT/bond status verified; IGST paid if applicable
- ☐ Inward supplies attracting reverse charge — declared as outward in Table 4D
- ☐ Taxable value match — GSTR-9 Table 4 vs GSTR-1 IGST/CGST/SGST columns
Section 3: ITC Reconciliation (Tables 6, 7 & 8)
⚠️ Critical Section: ITC errors are the most common reason for GSTR-9 notices. Reconcile every figure with GSTR-2B and books.
- ☐ Table 6A — ITC availed as per GSTR-3B: Sum all monthly GSTR-3B ITC (both auto and manual)
- ☐ ITC as per GSTR-2B for the year: Download annual GSTR-2B summary from portal
- ☐ Reconcile GSTR-2B vs books ITC: Identify mismatches > ₹10,000 — document reason
- ☐ Table 6B — ITC on inputs: Capital goods ITC separated from inputs/input services
- ☐ RCM ITC (Table 6C/6D): Verify RCM tax paid in 3B matches ITC claimed on RCM
- ☐ ITC on imports (IGST): Bill of Entry data vs books; customs IGST credit taken correctly
- ☐ Table 7 — ITC reversals: Rule 42 (mixed use), Rule 43 (capital goods), blocked credits (Sec 17(5))
- ☐ Ineligible ITC (Table 7H): Motor vehicles, personal expenses, food, club — all reversed
- ☐ Table 8 — ITC comparison: Verify auto-populated figures vs your working; explain excess or short
- ☐ Net ITC (6 minus 7): Cross-check with electronic credit ledger balance
Section 4: Tax Payment Reconciliation (Tables 9 & 10)
- ☐ Table 9 — Tax paid as declared in GSTR-3B: Sum all monthly tax paid (IGST/CGST/SGST/Cess)
- ☐ Reconcile cash vs ITC payment split: Match Electronic Cash Ledger payment entries
- ☐ Interest paid during the year: Include any interest paid for delayed filing/payment
- ☐ Late fee paid: Capture all late fee paid in cash ledger during the FY
- ☐ Table 10/11 — Previous year adjustments: Any amendments filed between April-September affecting previous FY
- ☐ Difference in tax liability: If GSTR-9 reveals higher liability, pay via DRC-03 before filing
Section 5: HSN/SAC Summary (Tables 17 & 18)
- ☐ Table 17 — HSN-wise outward supplies: Mandatory for taxpayers with turnover > ₹5 Cr (4-digit HSN); > ₹1.5 Cr (2-digit)
- ☐ Table 18 — HSN-wise inward supplies: Mandatory for turnover > ₹5 Cr
- ☐ Verify HSN codes: Match with product master; confirm correct digit level as per turnover slab
- ☐ HSN taxable value & tax split: IGST/CGST/SGST correctly allocated per HSN line
- ☐ Auto-populated HSN data: Review system data vs your working — correct any misclassifications
Section 6: Final Review Before Filing
- ☐ GSTR-9C applicability: If turnover > ₹5 Cr, GSTR-9C (reconciliation statement) must be filed simultaneously
- ☐ Nil return check: If no outward supply & no ITC, confirm nil GSTR-9 filing
- ☐ Digital signature ready: DSC or EVC of authorised signatory working on GSTN portal
- ☐ GSTR-9 preview: Download and review the JSON/PDF preview before submitting
- ☐ Outstanding liabilities cleared: All DRC-03 payments done; no pending demands
- ☐ File GSTR-9 before 31 December: Confirm ARN received and GSTR-9 status shows “Filed”
Quick Reference: Key Penalty Rates
| Default | Penalty / Consequence |
|---|---|
| Late filing of GSTR-9 | ₹200/day (₹100 CGST + ₹100 SGST), max 0.25% of turnover |
| ITC excess claimed | 100% penalty + interest @24% p.a. |
| Short payment of tax | 10% of tax or ₹10,000 (whichever is higher) |
| Fraud / suppression | 100% of tax due + prosecution if > ₹5 Cr |
| Non-filing after notice | Best judgment assessment under Sec 62 |
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