The Bombay Chartered Accountants’ Society (BCAS) has submitted a representation to the Government seeking an extension of at least three months in the due date for filing the Goods and Services Tax (GST) Annual Return in FORM GSTR-9 and the Reconciliation Statement in FORM GSTR-9C for the Financial Year 2024–25.
In its representation dated 11th December 2025, BCAS highlighted that taxpayers and professionals are facing significant practical and technical challenges due to extensive and substantive amendments introduced in the annual return and reconciliation forms through recent notifications, including Notification Nos. 12/2024-CT and 13/2025-CT.
Key reasons cited for seeking extension
BCAS stated that the cumulative impact of multiple changes has resulted in a considerable compliance burden, warranting additional time for accurate filing. The major concerns raised include:
- Procedural constraints: For FY 2024–25, FORM GSTR-9 can be filed only after submission of all GSTR-1 and GSTR-3B returns for the year, effectively reducing the time available for preparing the annual return.
- Increased complexity in ITC reporting: Mandatory granular disclosures, rule-wise break-up of Input Tax Credit (ITC) reversals, segregation of cross-year ITC, and introduction of new tables have significantly increased preparation and reconciliation efforts.
- Revised reconciliation framework: The delinking of Net ITC between GSTR-3B and GSTR-9 from FY 2024–25 onwards requires re-engineering of existing reconciliation processes, increasing the risk of inadvertent errors.
- System and process upgrades: Taxpayers and professionals require adequate time to understand the amendments, train personnel, and upgrade accounting and ERP systems to comply with revised reporting requirements.
- Challenges in GSTR-9C preparation: Withdrawal of long-standing relaxations in GSTR-9C has made turnover and ITC reconciliation with audited financial statements more time-consuming and complex.
Impact of frequent amendments and clarifications
BCAS noted that annual GST compliance forms have undergone numerous amendments over the years and that frequent changes, coupled with clarifications issued late in the compliance cycle, add to administrative challenges and delay compliance readiness.
Dependency on audited financial statements
The Society also pointed out that filing of FORM GSTR-9C is dependent on the completion of statutory audits. With the extension of tax audit due dates to 10 November, the effective time available for preparing and filing GST annual returns has been significantly compressed.
Request for reasonable transition period
In view of the above, BCAS has urged the Government to provide a reasonable transition period by extending the due date for filing GSTR-9 and GSTR-9C for FY 2024–25, to enable accurate compliance and reduce the risk of unintended errors and disputes.
Source #ET
