One financial year, two GST rate books — this year's GSTR-9 has to add up both

Every August, someone from a mid-sized trading or manufacturing firm asks the same question: "Do we have to file GSTR-9 this year?" Most years the answer is a straightforward look-up against turnover. This year the question has a second half nobody has had to think about before, because the return itself now has to add up tax paid under two different GST rate structures inside the same twelve months.

Who actually has to file — Section 44 and Rule 80

Section 44 of the CGST Act, 2017 requires every registered person to file an annual return. Rule 80 of the CGST Rules sets the carve-outs, and CBIC's Notification No. 15/2025-Central Tax (17 September 2025) made one of them permanent: registered persons with aggregate turnover up to ₹2 crore in a financial year are exempt from filing GSTR-9 altogether, from FY 2024-25 onwards. Earlier this exemption was renewed year by year through a fresh notification each time; now it simply applies, every year, without anyone having to check the notification list in December to find out.

In plain terms: a Ring Road sarees trading firm doing ₹1.8 crore a year has nothing to file under GSTR-9, this year or next. A diamond-cutting or embroidery unit turning over ₹6 crore has to file it — and, because it crosses the next threshold too, has to file GSTR-9C as well.

GSTR-9C: "self-certified" does not mean "unimportant"

GSTR-9C, the reconciliation statement, is required only where aggregate turnover exceeds ₹5 crore (Rule 80(3)). Since FY 2020-21, it no longer needs a chartered accountant's or cost accountant's certification — the taxpayer self-certifies it. What that removed was a signature requirement, not the underlying reconciliation work: the statement still has to explain, line by line, why the turnover in your audited financial statements matches, or doesn't, the turnover declared across the year's GST returns.

A textile processing house in Sachin turning over ₹7 crore a year, whose audited profit-and-loss figure differs from its declared GST turnover by even 2–3%, will draw a departmental query the reconciliation statement is supposed to pre-empt. Job-work value, stock transfers between units, and export turnover are the usual explanations — but only if they are written down clearly, not assumed to be obvious.

The complication unique to this year: two rate books in one return

On 3 September 2025 the GST Council, at its 56th meeting, recommended collapsing the old four-slab structure — 5%, 12%, 18% and 28% plus compensation cess — into two main rates, 5% and 18%, with a 40% rate for sin and luxury goods. CBIC notified the change through Notification No. 9/2025-Central Tax (Rate), dated 17 September 2025 and effective 22 September 2025. Compensation cess was scrapped on everything except cigarettes, chewing tobacco (zarda, gutkha), unmanufactured tobacco and bidi, which kept the old rates for the time being.

FY 2025-26 runs from 1 April 2025 to 31 March 2026 — 174 days under the old structure, 191 days under the new one. Every month's GSTR-1 and GSTR-3B during the year already used whichever rate applied to that month, so nothing needs to be re-filed. What GSTR-9 does not do is split Table 4 (outward supplies) or Table 9 (tax paid) by rate period — it only asks for annual totals. The burden of showing why a product's tax rate, and therefore the tax collected on it, looks different in the first half of the year versus the second sits entirely in your own working papers.

A concrete example: a Surat trader in corrugated packaging boxes and cartons — a business almost every textile unit in the city deals with — was taxed at 12% until 21 September and folded into the 18% slab from 22 September. Six months of invoices at one rate, six months at another, on the identical product, to the identical customers. Filed as a single annual total with no explanation, that swing looks like an error to anyone reviewing the file later — a GST officer scrutinising the return, or a bank credit officer comparing GST turnover against a project report, the same cross-checking exercise described in an earlier article on why banks reject loan files. A one-page rate-wise turnover note, prepared once, settles the question before it is even asked.

What changed inside the form itself

Two changes catch people off guard. First, Table 8A of GSTR-9 — credit available as per your GST returns — now auto-populates from the Invoice Management System and GSTR-2B, rather than being computed separately. A Katargam trading firm that left forty invoices sitting in "Pending" in IMS since March will see all forty pulled into Table 8A automatically, with no separate flag telling anyone why the figure looks the way it does. Second, ITC brought forward from the prior financial year but actually claimed during FY 2025-26 now has to be reported separately, in Table 6A1, rather than lumped in with the current year's own credit.

What missing 31 December actually costs

Section 47(2) of the CGST Act fixes the late fee for a delayed annual return at ₹100 a day under CGST and ₹100 a day under SGST — ₹200 a day combined — capped at 0.5% of the taxpayer's turnover in the relevant state (0.25% CGST, 0.25% SGST). For a firm turning over ₹4 crore in Gujarat, that cap alone is ₹2,00,000. Unlike a missed GSTR-3B, a missed GSTR-9 doesn't block next month's filing, which is exactly why it's easy to let slip — but it does tend to be the kind of gap the department notices when it selects returns for scrutiny.

Sources

This article is general information, not professional advice. Rules change; verify current provisions or contact the office for advice on your situation.