The annual return is where a year of monthly filings has to agree with itself — and with your books. Most years that is tedious. For FY 2025-26 it is genuinely tricky, because GST 2.0 switched the rate schedule on 22 September 2025, cutting the year into two regimes that both live inside one GSTR-9.
Who files what
| Aggregate turnover (FY 2025-26) | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional (often worth filing) | Not required |
| ₹2 crore – ₹5 crore | Mandatory | Not required |
| Above ₹5 crore | Mandatory | Mandatory, self-certified |
Composition taxpayers are outside this table — their annual statement is GSTR-4. And the deadline discipline has teeth now: under the three-year bar, an annual return left unfiled for three years past its due date is barred permanently.
The tables where the work lives
- Tables 4–5 (outward supplies): your GSTR-1s consolidated, split across taxable, exempt and non-GST — this year, reconciled across two rate regimes.
- Tables 6–8 (ITC): credit availed per 3B against what the system shows, with the gap explained. The IMS accept/reject trail makes this cleaner for FY 2025-26 than it was — if you actually used it.
- Tables 10–13 (spillover): FY 2025-26 transactions corrected or credited in FY 2026-27 returns up to the specified period.
- Table 17 (HSN): HSN-wise outward summary — four digits up to ₹5 crore turnover, six digits above.
The rate-switch reconciliation
The 22 September 2025 boundary creates four specific traps we are seeing in FY 2025-26 files:
- Credit notes that cross the line. A note issued in October 2025 against an August 2025 invoice carries the old rate. Notes issued at the new rate against old-rate invoices create mismatches that surface only at annual-return stage.
- Advances and time of supply. Advances received before the switch and adjusted after it follow time-of-supply rules, not invoice dates.
- Price renegotiations. Contracts repriced “GST-neutral” in September–October 2025 often were not; the differential shows up as a rate-wise anomaly in table 4.
- Stock and ITC assumptions. Slab changes altered the economics of inventory bought at old rates and sold at new ones — the books entry is fine, but the 9C reconciliation must explain the margin movement.
Late fees
| Turnover | Late fee / day | Cap |
|---|---|---|
| Up to ₹5 crore | ₹50 | 0.04% of state turnover |
| ₹5–20 crore | ₹100 | 0.04% of state turnover |
| Above ₹20 crore | ₹200 | 0.5% of state turnover |
A sensible timeline
- September–October 2026: books-to-returns reconciliation, and any FY 2025-26 corrections pushed into monthly returns before the 30 November specified period closes.
- November 2026: draft GSTR-9 tables, resolve ITC gaps, quantify any DRC-03 payments.
- December 2026: file 9 and 9C with margin — not on the 31st, when the portal remembers it is a government portal.
How we can help
Our GSTR-9 and 9C service does the reconciliation, not just the form-filling: books to 3B to 1 to 2B, the rate-switch cut-over, spillover tables and the 9C statement. Retainer clients on our monthly GST filing get the annual return built from reconciliations that already exist — which is the cheap way to do this. If your FY 2025-26 monthly returns need repair first, start now; December queues are real.
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This article is general information, not tax advice. Thresholds and dates can change by notification; confirm specifics for your business before acting.