What is GSTR 9? Filing Process, Turnover Limit and Late Fees Explained

Introduction

Form GSTR-9 is the annual return under GST law that must be filed by registered taxpayers who operate as regular taxpayers, including SEZ units and SEZ developers. It consolidates the details of outward and inward supplies, input tax credit, tax paid, and other related activities for a financial year. This return acts as a reconciliation tool and helps the tax authorities assess compliance.

Understanding what is GSTR 9, who is required to file GSTR 9, what is the due date for GSTR 9, and how to file the GSTR 9 annual return is essential for timely and accurate compliance. The GSTR 9 turnover limit determines mandatory filing based on business size, while missing the deadline may attract penalties under the GSTR 9 late fees provisions. The late fee for GSTR 9 is calculated daily, with maximum limits specified by law.

This article provides a complete overview of the GSTR 9 filing process, including eligibility, due dates, turnover limits, step-by-step filing instructions, and penalty structures to help taxpayers file correctly and avoid non-compliance.

What is GSTR 9?

Form GSTR-9 is the annual return prescribed under the GST law that must be filed by registered taxpayers who operate as regular taxpayers, including Special Economic Zone (SEZ) units and SEZ developers. Form GSTR-9 is an annual return to be filed once for each financial year by the registered taxpayers who were regular taxpayers, including SEZ units and SEZ developers.

This comprehensive document requires taxpayers to furnish consolidated details of all their transactions, including purchases, sales, input tax credit claimed, refunds received, and demands created during the respective financial year. The annual return serves multiple purposes within the GST framework. It acts as a reconciliation tool between the data reported in monthly returns (GSTR-1 and GSTR-3B) and the actual business transactions conducted during the year. Additionally, it provides tax authorities with comprehensive information to assess the taxpayer’s compliance status and identify any discrepancies that may require further scrutiny.

Who is Required to File GSTR 9?

The filing obligation for GSTR-9 extends to specific categories of registered taxpayers under the GST regime. Form GSTR-9 is to be filed by a person who is registered as a normal taxpayer, including SEZ unit or SEZ developer, and the taxpayers who have withdrawn from the composition scheme to normal taxpayer any time during the financial year.

Mandatory Filing Categories

The following categories of taxpayers are mandatorily required to file GSTR-9:

1. Regular Taxpayers: All persons registered as normal taxpayers under GST must file GSTR-9, subject to turnover thresholds specified by the government.
2. SEZ Units and Developers: Special Economic Zone units and developers operating under regular taxpayer status are mandated to file annual returns regardless of their turnover.
3. Composition Scheme Withdrawals: Taxpayers who opted out of the composition scheme during the financial year must file GSTR-9 for the period they operated as regular taxpayers.
4. Cancelled Registration Cases: Yes, the annual return needs to be filed even if the taxpayer has had their registration cancelled during the said financial year.

Exempted Categories

While the GST law mandates GSTR-9 filing for regular taxpayers, the government has provided relief to certain categories through notifications. Small taxpayers with aggregate turnover up to specified limits may be exempted from this requirement to reduce the compliance burden.

GSTR 9 Turnover Limit

The concept of the GSTR-9 turnover limit filing has evolved significantly since the implementation of GST. The government has established specific thresholds to balance compliance requirements with ease of doing business for smaller enterprises.

Current Turnover Thresholds for GSTR 9

The following table outlines the current turnover limits for GSTR-9 filing:

Financial Year	Turnover Threshold	Filing Requirement	Status
2019-20	Above Rs. 2 crores	Mandatory	Optional for turnover up to Rs. 2 crores
2020-21	Above Rs. 2 crores	Mandatory	Optional for turnover up to Rs. 2 crores
2021-22 onwards	Above Rs. 2 crores	Mandatory	Optional for turnover up to Rs. 2 crores

Special Cases for Turnover Limits

1. SEZ Units and Developers: All SEZ units and developers must file GSTR-9 regardless of their turnover level.
2. E-commerce Operators: Electronic commerce operators are required to file GSTR-9 irrespective of their turnover.
3. Input Service Distributors: ISD entities must file annual returns without any turnover threshold exemption.

What is the Due Date for GSTR 9?

The statutory due date for filing GSTR-9 is clearly defined under the GST regulations. The due date for filing Form GSTR-9 for a particular financial year is 31st December of the subsequent financial year or as extended by the Government through notification from time to time.

Due Date Schedule

The following table provides the due date schedule for the last five financial years:

Financial Year	Original Due Date	Extended Due Date (if applicable)
2020-21	December 31, 2021	Extended multiple times
2021-22	December 31, 2022	Extended multiple times
2022-23	December 31, 2023	Extended multiple times
2023-24	December 31, 2024	Filed as per schedule
2024-25	December 31, 2025	To be notified

Extension Provisions

Yes, the date of filing of Form GSTR-9 can be extended by the Government through a notification. The government has historically extended due dates to provide taxpayers with additional time to ensure accurate compliance, particularly during the initial years of GST implementation and during exceptional circumstances such as the COVID-19 pandemic.

GSTR 9 Filing Process

Step 1: Portal Access and Login Navigate to the official GST portal (www.gst.gov.in) and log in using valid credentials. Navigate to Services > Returns > Annual Return to file Form GSTR-9.

Step 2: Selection of Financial Year. Select the appropriate financial year for which the annual return is being filed.

Step 3: Auto-Population of Data The system automatically populates certain fields from previously filed monthly returns. Tables below in Form GSTR-9 have auto-populated data from already filed Form GSTR-1 and Form GSTR-3B of the relevant financial year:

• Table 4: Supply details from GSTR-1 and GSTR-3B
• Table 5: Non-taxable supply details
• Table 6A: ITC details from GSTR-3B
• Table 9: Tax payment details

Step 4: Manual Data Entry and Verification. Taxpayers must manually enter information in tables not auto-populated by the system:

• Verify auto-populated data for accuracy
• Enter additional details in the relevant tables
• Ensure HSN-wise summaries are complete
• Add any missing transaction details

Step 5: Data Reconciliation and Corrections. Compare auto-populated data with actual business records and make necessary corrections where permissible. Note that certain fields cannot be edited after auto-population.

Step 6: Computation of Liabilities After the COMPUTE LIABILITIES button is clicked, details provided in various tables are processed on the GST Portal at the back end, and Late fee liabilities, if any, are computed.

Step 7: Payment of Outstanding Dues. Clear any outstanding tax liabilities or late fees before proceeding with the filing. Additional liability not reported earlier can be declared and paid through Form GST DRC-03.

Step 8: Preview and Final Verification Review the return using the preview function available in both PDF and Excel formats. Verify all entries for accuracy and completeness.

Step 9: Filing and Digital Authentication Submit the return using Digital Signature Certificate (DSC) or Electronic Verification Code (EVC) after completing the declaration.

Alternative Filing Methods

Yes, Form GSTR-9 return can be filed through the offline tool. This option provides flexibility for taxpayers who prefer to prepare their returns offline before uploading to the portal.

How to File GSTR 9 Annual Return

The step-by-step GSTR-9 filing process, annual return, involves specific technical procedures that must be followed precisely:

Technical Filing Procedure

Login and Navigation:

1. Access the GST Portal using registered credentials
2. Navigate to Services > Returns > Annual Return
3. Select Form GSTR-9 for the relevant financial year

Data Preparation:

1. Download system-computed values for reference
2. Download GSTR-1 and GSTR-3B summaries in PDF format
3. Download Table 8A document details in Excel format for reconciliation

Form Completion:

1. Review auto-populated data from monthly returns
2. Complete manual entry fields with accurate information
3. Ensure HSN codes are properly classified (minimum 2-digit codes required)
4. Verify all monetary values and calculations

Liability Computation:

1. Click ‘COMPUTE LIABILITIES’ to process the entered data
2. Review calculated late fees and additional tax liabilities
3. Ensure sufficient balance in the Electronic Cash Ledger

Payment and Filing:

1. Pay any outstanding liabilities through the Electronic Cash Ledger
2. Create a challan for additional cash requirements if needed
3. Preview the draft return in PDF/Excel format
4. Complete the declaration and select an authorized signatory
5. File the return using DSC or EVC

GSTR 9 Late Fees

Late filing of GSTR-9 attracts specific penalties and fees as prescribed under the GST law. Understanding these provisions is essential for maintaining compliance and avoiding unnecessary financial burden.

Late Fee Structure for GSTR 9

Yes, there is a late fee for GSTR-9 beyond the due date. The late fee calculation follows a specific methodology:

Component	Rate	Maximum Limit
CGST Late Fee	Rs. 100 per day	0.25% of turnover in the state
SGST Late Fee	Rs. 100 per day	0.25% of turnover in the state
Total Daily Late Fee	Rs. 200 per day	0.5% of aggregate turnover

Special Relief Measures for Late Fee for GSTR 9

The government has provided significant relief for pending GSTR-9 returns:

• Concessional Late Fee: Taxpayers who file pending GSTR-9 for Financial Years 2017-18, 2018-19, 2019-20, 2020-21, and 2021-22 shall pay a maximum late fee of Rs. 20,000.
• NIL Return Late Fee: For taxpayers filing NIL returns where no business activity occurred, reduced late fees apply.

Penalty Implications Beyond Late Fees

No. You can’t file Form GSTR-9 without payment of the late fee for Form GSTR-9 if the same is filed after the due date. Beyond late fees, non-compliance with GSTR-9 filing requirements may attract additional penalties under Section 125 of the CGST Act, which can range up to Rs. 25,000 and may be imposed by both Central and State GST authorities.

Conclusion

Filing the annual GST return is a crucial compliance responsibility for all regular taxpayers under the GST regime. Understanding what is GSTR 9 and who is required to file GSTR 9 ensures that taxpayers meet their obligations without confusion. Awareness of the due date for GSTR 9 is equally important to avoid penalties and maintain a clean compliance record.

The GSTR 9 filing process involves data reconciliation, verification, and submission through the GST portal or offline tools. Knowing how to file the GSTR 9 annual return step-by-step helps taxpayers complete the process smoothly.

The GSTR 9 turnover limit determines whether filing is mandatory based on annual turnover, while timely action helps avoid the burden of GSTR 9 late fees. For those missing the deadline, the late fee for GSTR 9 can add up significantly and even attract further penalties if non-compliance continues.

Taxpayers are encouraged to review their records, reconcile their data, and file their annual return well before the deadline to ensure full compliance under GST law.

Bibliography

• GST Portal, ‘FAQs > About Form GSTR-9’ (GST Portal) https://tutorial.gst.gov.in/userguide/returns/FAQs_gstr9.htm accessed 10 June 2025.
• GST Portal, ‘Manual > GSTR-9 – Goods and Services Tax’ (GST Portal) https://tutorial.gst.gov.in/userguide/returns/Manual_gstr9.htm accessed 10 June 2025.
• ClearTax, ‘GSTR-9 Annual Return: Due Date, Applicability, Turnover Limit, Format, Eligibility, Rules’ (ClearTax, 26 March 2025) https://cleartax.in/s/gstr-9-annual-return accessed 10 June 2025.
• IndiaFilings, ‘A Comprehensive Guide to File GSTR-9’ (IndiaFilings) https://www.indiafilings.com/learn/a-comprehensive-guide-to-file-gstr-9/ accessed 10 June 2025.
• Tax2win, ‘GSTR 9: Annual GST Return Filing Form Procedure & Due Date’ (Tax2win, 14 August 2019) https://tax2win.in/guide/gstr-9-annual-return accessed 10 June 2025.

Author: Suhani Sharma