GSTR-9 is the annual return that a regular taxpayer under the GST regime must file. It reconciles inward and outward supplies, tax liabilities, input tax credit (ITC) claimed, and refunds for the financial year. It is essentially a “once-a-year wrap-up” return, summarising all monthly/quarterly filings.

GSTR-9 Applicability

All GST-registered taxpayers must file their GSTR 9. The following are NOT required to file GSTR 9:

1. Taxpayers opting for the composition scheme (they must file GSTR-9A).
2. Casual taxable person
3. Input service distributors
4. Non-resident taxable persons
5. Persons paying TDS under section 51 of the CGST Act
6. Person collecting TCS under section 52 of the CGST Act

GSTR-9 Turnover Limit

1. GSTR-9 (Annual Return) is optional for businesses with turnover up to Rs 2 crore since FY 17-18 onwards till FY 2023-24. Every year, the GST department notifies the threshold turnover limit above which it is mandatory to file GSTR-9.
2. As per the Central Tax notification dated 17 September 2025, registered persons whose aggregate turnover during a financial year does not exceed ₹ 2 crore are exempt from filing GSTR-9 from FY 2024-25 onwards.
3. if your turnover is above ₹ 2 crore, you must file; if it is up to ₹ 2 crore, you’re exempt (for GSTR-9) from FY 2024-25 onwards.

GSTR-9 Due Date

GSTR-9 last date for FY 2024-25 is 31^st December 2025. GST annual return due date or GSTR-9 due date is 31st of December of the next year for a particular financial year.

GSTR-9 Filing Steps

1. Finish the filing of GSTR-1 and GSTR-3B to date, especially for FY 2024-25.
2. Perform an in-depth ITC reconciliation and sales reconciliation from the beginning of the financial year to date.
3. Communicate with the vendors and customers about any gaps found upon reconciliation.
4. Make disclosures related to FY 24-25 using the government’s offline tool, or preferably by employing cloud-based software such as Clear for easy auto-fills and end-to-end filing.
5. Pay via DRC-03 any short payment of tax or excess ITC claims identified for FY 24-25.
6. File the GSTR-9 on the GST portal.

What Happens if GSTR-9 is Wrongly Filed?

If you do not submit the GSTR-9 in the expected structure or format as given by the GSTN, there arises a GSTR-9 schema validation error. So, the schema validation in GSTR-9 assists in verifying the entered data to check its correctness and if the data entered is as per the format provided on the GST portal. If there is any discrepancy, you will get a schema validation error code. Once you have rectified the issues, the system finally processes your GSTR-9 application.

Can we make corrections in GSTR-9?

No, corrections cannot be made in GSTR-9 once it’s filed. GSTR-9 is an annual return, and once submitted, it’s considered final by the GST department and cannot be altered. However, you can write to the department and check if you can submit corrections separately.

Automated Demand & Recovery Notices

What are these notices?

Under the GST regime, authorities may raise tax demands, interest, and penalties where they believe a taxpayer has underpaid tax, wrongly claimed ITC, misreported supplies, or not filed required returns. Much of this process is now automated or semi-automated. For example:

1. The “Automated Return Scrutiny Module” (ARSM) triggers notices in Form ASMT-10 when discrepancies are noticed in returns filed.
2. Thereafter, the taxpayer can respond via ASMT-11. Failure to respond may lead to show-cause notices under Sections 73 and 74 of the CGST Act.
3. For demands and recoveries, the process involves forms such as DRC-01 (statement of demand), DRC-03 (payment), and DRC-06 (reply to demand).

Typical triggers of automated notices

Some common triggers include:

1. Mismatch between outward supplies (GSTR-1) and summary (GSTR-3B) filings.
2. Claiming ITC, which does not match with supplier’s filing.
3. Filing returns late or non-filing of returns.
4. Unreported supplies, fraudulent claims, or unusual tax credits.
5. Annual return (GSTR-9) showing values inconsistent with earlier monthly/quarterly filings.

Demand and recovery process

1. The authority issues Form DRC-01 stating the tax, interest, or penalty amount for a certain period.

2. The taxpayer has the option to respond:

a. Pay the amount voluntarily via DRC-03; or

b. Respond/contest the demand via DRC-06 (or corresponding forms).

3. If the taxpayer fails to respond or pay within the time period (typically up to 3 months from service of the order), then recovery proceedings may commence. The authority may attach bank accounts, movable/immovable property, deduct refunds, etc.

4. Where non-fraud liability, Section 73 of the CGST Act applies; for fraud/misdemeanour, Section 74.

How to Respond When You Get an Automated Demand or Recovery Notice

Step 1: Read the notice carefully

When you receive a notice (ASMT-10, DRC-01, show-cause notice, etc.) log in to your GST portal → Services → User Services → View Notices & Orders.
Important details to check:

a. The form number and reference number.

b. Date of issue and whether a time limit to respond is specified.

c. The period covered and the quantum of demand specified (tax, interest, penalty).

d. Grounds or reasons for the demand (ITC mismatch, non-filing, etc.).
Failing to respond within the stipulated timeline may lead to an ex parte

Step 2: Gather your documents and facts

a. GSTR-1, GSTR-3B, and GSTR-9 (if already filed) for the period concerned.

b. Purchase registers, sales registers, ITC ledgers, e-way bills, invoices, bank statements, etc.

c. Invoices from suppliers, proof of payment of tax/ITC, adjustment notes, etc.

d. Explanation for any mismatches (e.g., import of services, timing differences, credit notes).
Organising your documents in chronological order and ensuring they align with what you filed will strengthen your response.

Step 3: Decide how you will respond

a. If you accept the demand, you can pay the tax, interest, or penalty via DRC-03 (or the relevant form). After payment, the officer issues DRC-04 (acknowledgment) and DRC-05 (demand closed).

b. If you contest the demand, you should file a reply via DRC-06 (for demands) or ASMT-11 (for automated scrutiny module) within the stipulated time. State your case, attach evidence, ask for clarification, defend your position.

c. If you think there is partial liability, explain the portion you accept, and dispute the rest. Section 73 allows this flexibility.

Step 4: File your reply on time

a. Reference the notice number, date, and

b. Respond specifically to each item in the notice.

c. Provide your explanation for the differences and attach supporting documents.

d. Maintain a cooperative professional tone in all correspondence.

e. Retain copies/screenshots of the submission for your records.

Step 5: Monitor what happens next

a. The officer may drop proceedings (via ASMT-12 or DRC-05) if satisfied.

b. If not satisfied, a show-cause notice may follow under Sections 73/74 (requiring personal hearing, further evidence).

c. If demand is confirmed, you may pay and/or file an appeal (within 3 months) before the appropriate tribunal/authority. Note: once 3 months pass without appeal or payment, recovery steps may start.

d. In recovery mode, the authority can draw down refunds, attach bank accounts, and recover as arrears of land revenue.

Step 6: Document your compliance / rectify future issues

a. Keep detailed records of your filing history, reconciliations, and correspondence with the tax authorities.

b. If you find errors in your GSTR-1/3B or earlier filings, consider rectifying them (depending on permitted amendments) before further notice.

c. Use the experience to strengthen internal controls—ensure accurate supplier–recipient data matching, timely filings, correct ITC claims, and proper documentation.

Conclusion

For FY 2024-25, the window for filing GSTR-9 starts now and your focus should be on accurate, timely reconciliation and submission. But equally important is awareness of the risk of automated notices and demands that could arise from the data you file. By proactively reconciling your records, aligning your monthly/quarterly filings, and preparing to respond (if needed) to any demand/notice, you safeguard your business from escalation into costly litigation or recovery actions.

For any clarifications or queries, please feel free to reach out to us at admin@fintracadvisors.com

Disclaimer

The content published on this blog is for informational purposes only. The opinions expressed here are solely those of the respective authors and do not necessarily reflect the views of Fintrac Advisors. No warranties are made regarding this information’s completeness, reliability, or accuracy. Any actions taken based on the information presented in this blog are solely at the reader’s risk, and we will not be liable for any losses or damages resulting from its use. It is recommended that professional expertise be sought for such matters. External links on this blog may direct users to third-party sites beyond our control. We do not take responsibility for their nature, content, or availability.