A professional body representing tax practitioners submitted a detailed representation to the Union Finance Minister, the Maharashtra Chief Minister, and GST authorities seeking an extension of the due date for filing FORM GSTR-9 and FORM GSTR-9C for FY 2024–25 up to 31 January 2026. The request is based on substantial structural and procedural changes introduced in the annual return and reconciliation framework through multiple notifications during the year, followed by detailed FAQs and GSTN advisories issued as late as October and December 2025. These changes significantly increased the complexity of ITC reporting, cross-year adjustments, and turnover reconciliation, while withdrawing earlier relaxations and mandating granular disclosures requiring manual data reconstruction. The representation highlights that effective compliance is dependent on finalised audited financial statements, many of which were completed close to extended audit deadlines, leaving insufficient time for accurate GST reconciliation. It cautions that the compressed timeline heightens the risk of unintended errors, avoidable disputes, and litigation, and seeks a pragmatic extension to ensure accurate, litigation-free compliance.

The Malad Chamber of Tax Consultants

Date: 17th December 2025

To,
Smt. Nirmala Sitharaman,
Hon'ble Minister of Finance
North Block,
Ministry of Finance,
Government of India
New Delhi – 110001

Shri. Devendra Fadanvis
Hon'ble Chief Minister
State of Maharashtra
Mantralaya, Mumbai 400 032

Subject: Request for extension of due date for filing FORM GSTR-9 and FORM GSTR-9C for Financial Year 2024-25.

Respected Madam / Sir,

The Malad Chamber of Tax Consultants (MCTC), a non-profit professional body established in 1978, represents over 1,350 members comprising Chartered Accountants, Advocates, Company Secretaries, Cost Accountants, and Tax Practitioners. Registered under the Societies Registration Act, 1860, and the Bombay Public Trusts Act, 1950, the Chamber has consistently worked towards disseminating knowledge and creating awareness among professionals, taxpayers, and the public through study circles, seminars, workshops, refresher courses, and public meetings. We also provide practical training to students and make effective representations before government authorities on taxation and allied matters.

The Malad Chamber of Tax Consultants (MCTC) respectfully submits this representation on behalf of its members and the wider taxpayer community engaged in Goods and Services Tax compliances.

At the outset, we acknowledge the continued efforts of the Government, the GST Council and the CBIC in strengthening the GST framework through statutory amendments, notifications, circulars and system-based validations, with the objective of improving accuracy in reporting and ensuring correct availment of Input Tax Credit. The intent behind these measures is fully appreciated.

However, it is respectfully submitted that for Financial Year 2024-25, the annual compliance framework relating to FORM GSTR-9 and FORM GSTR-9C has undergone substantial structural and procedural changes, introduced through notifications and followed by multiple clarifications issued during the compliance cycle. The cumulative impact of these changes has resulted in genuine and widespread practical difficulties in achieving accurate compliance within the presently prescribed timelines.

Nature of amendments and impact of delegated legislation:

For FY 2024-25, the structure, instructions and reporting requirements of FORM GSTR-9 and FORM GSTR-9C have been materially altered pursuant to notifications issued during the year, including notifications issued in June 2024, December 2024, and mid-2025, which revised reporting tables, instructions and reconciliation architecture.

These changes were subsequently supplemented by GSTN FAQs and advisories, including detailed FAQs issued in October 2025 and further system advisories released in early December 2025, i.e., during the annual return filing period itself.

These amendments are not in the nature of minor procedural refinements. They represent a restructuring of annual disclosure and reconciliation logic, particularly in relation to:

• Input Tax Credit reporting,

• cross-financial-year ITC adjustments, and

• turnover reconciliation between returns and audited financial statements.

Several practical relaxations that were available for earlier years were withdrawn, while new granular disclosures were made mandatory, requiring taxpayers to reconstruct historical data based on parameters that were not required at the time of original transactions.

Effect of subsequent clarifications and GSTN advisories:

While the issuance of FAQs and advisories by GSTN is appreciated, it is respectfully submitted that the timing of such clarifications has materially impacted compliance.

Clarifications issued as late as October and December 2025 required taxpayers and professionals to revisit reconciliations already prepared in good faith, leading to repeated reworking of data, recalibration of reporting positions, and additional verification exercises.

In several instances, the clarifications introduced interpretational nuances rather than simple procedural guidance, thereby necessitating professional judgment and increasing the time required to finalise annual returns.

Specific difficulties in FORM GSTR-9:

FORM GSTR-9 for FY 2024-25 now mandates significantly enhanced granularity in ITC reporting, including:

• Separate disclosure of ITC pertaining to earlier financial years but availed in the current year,

• Rule-wise identification of reversals and re-availments, and

• Reconciliation based on revised auto-population logic driven by system-computed data.

Many of these data points were not historically captured in accounting systems in the manner now required. Consequently, taxpayers are compelled to rely on manual extraction and reconstruction of data, increasing the effort involved and the risk of unintended mismatches.

Further, revisions in auto-population logic, particularly in tables relating to ITC reconciliation, have resulted in situations where system-derived figures do not align with taxpayers' records despite correct underlying compliance, thereby substantially increasing reconciliation effort and compliance uncertainty.

Increased reconciliation burden under FORM GSTR-9C:

FORM GSTR-9C, which is intended to reconcile GST returns with audited financial statements, has also undergone a substantial increase in complexity.

The revised framework requires detailed break-ups of turnover adjustments and cross-year ITC reconciliations that were earlier permitted to be reported in a consolidated manner. Certification now demands careful alignment of:

• Audited Financial Statements,

• GSTR-3B disclosures, and

• Annual Return Figures,

each governed by distinct legal and accounting principles. This has materially increased the professional time required to ensure accurate and defensible reconciliation.

Dependency on audited financial statements and compressed timelines:

It is respectfully submitted that filing of FORM GSTR-9C, and even meaningful preparation of FORM GSTR-9, is inextricably linked to the completion and finalisation of audited books of account.

For FY 2024-25, statutory and tax audit due dates were extended by the competent authorities, and in many cases audits were completed only close to or after the extended deadlines. Until such audits are concluded and financial statements are finalised, it is practically and legally untenable to undertake final GST annual reconciliations.

Without audited turnover figures, expense classifications, and final ITC eligibility determinations, taxpayers are not in a position to file accurate GSTR-9 and GSTR-9C. Consequently, the effective time available after completion of audits to comply with the revised GST annual return framework has been extremely limited.

Given the scale of amendments, clarifications and reconciliation requirements applicable for FY 2024-25, the residual period post-audit has proved grossly inadequate for compliant and error-free filing.

Cumulative impact and risk of unintended non-compliance

The cumulative effect of:

• substantial amendments introduced through notifications during FY 2024-25,

• multiple clarifications issued in October and December 2025,

• revised system logic and auto-population dependencies, and

• dependency on audited and finalised financial statements,

has resulted in a compliance environment where even diligent taxpayers face a heightened risk of unintentional errors.

Such errors, arising from transitional and systemic constraints rather than deliberate non-compliance, may lead to avoidable notices, disputes and litigation, which would neither serve the interests of revenue nor further the objective of ease of doing business.

Humble request for extension:

In view of the foregoing, and in the interest of ensuring accurate, fair and litigation-free compliance, it is most respectfully requested that the Hon'ble Authorities may consider granting a general extension up to 31st January 2026 for filing FORM GSTR-9 and FORM GSTR-9C for FY 2024-25.

This would provide taxpayers and professionals with adequate time to assimilate the amended legal framework, complete post-audit reconciliations, and file annual returns with the accuracy and completeness envisaged under law.

Conclusion:

This representation is made not to seek dilution of statutory obligations, but to request a reasonable and pragmatic transition period, considering the timing and scale of changes introduced through delegated legislation and subsequent clarifications.We trust that the Hon'ble Authorities will appreciate the genuine practical difficulties outlined above and consider this request sympathetically.

Thanking you,
For The Malad Chamber of Tax Consultants (MCTC)

CC to:
The Chairperson
Central Board of Indirect Taxes & Customs (CBIC)
North Block, Ministry of Finance,
Government of India
New Delhi – 110001

The GST Council Secretariat
Office of the GST Council Secretariat
5th Floor, Tower II, Jeevan Bharti Building
Janpath Road, Connaught Palace,
New Delhi – 110001

Adv. Ashish Jaiswal
Hon'ble Minister of State, Finance
State of Maharashtra
Mantralaya, Mumbai 400 032

The Hon'ble Commissioner of State Tax
GST Bhavan, Mazgaon
Mumbai. Maharashtra.

Shri. Piyush Goyal
Hon'ble Commerce and Industry Minister of India
Lok Kalyan Karyalay – 56, Balasinor Society, SV Road, Opp Fire Brigade, Kandivali West,
Mumbai – 400067.Maharashtra