The last date for taking input tax credit (ITC) for FY 2025-26 and the due date for filing the FY 2025-26 annual return are not the same. Treating them as one date can cost a business eligible credit. With 30 November 2026 close, businesses should finish their ITC review first and file GSTR-9 and GSTR-9C after that.

1. What section 16(4) says

Under section 16(4) of the CGST Act, a registered person cannot take ITC on an invoice or debit note after the 30th day of November following the end of the financial year to which it relates, or after furnishing the relevant annual return, whichever is earlier.

This is a time limit, not a permission to claim whatever is in the purchase ledger. All other conditions continue to apply, including possession of a tax invoice, the invoice appearing in GSTR-2B (section 16(2)(aa)), receipt of goods or services, payment of tax by the supplier, payment to the supplier within the prescribed time, and the blocked-credit list in section 17(5). Special situations covered by sections 16(5) and 16(6) should be examined separately.

2. The annual return: who files what

The thresholds apply to aggregate turnover, which is computed on an all-India basis for the PAN, not for a single GSTIN. Composition taxpayers, input service distributors, non-resident taxable persons and certain other categories have their own requirements.

• GSTR-9C is self-certified. A separate CA-certified GST audit report is no longer required.
• The portal is open. GSTN has enabled GSTR-9 and GSTR-9C for FY 2025-26. The filing option appears only after all GSTR-1 and GSTR-3B returns for the year are filed.
• Reporting relaxations: certain table-level relaxations in GSTR-9 and GSTR-9C have been extended to FY 2025-26 onwards by a notification dated 26 October 2026. Check the current form instructions before filing.
• The exemption does not extend the ITC deadline. A business below Rs. 2 crore that does not file GSTR-9 is still bound by 30 November 2026 for taking FY 2025-26 ITC.

3. GSTR-9 and GSTR-9C are one annual return

CBIC Circular No. 246/03/2025-GST dated 30 January 2025 clarifies that, where GSTR-9C is required, the complete annual return consists of both GSTR-9 and GSTR-9C. Filing GSTR-9 alone does not complete the return. Late fee under section 47(2) is not levied separately for each form; it runs from the due date until the complete annual return, including GSTR-9C, is filed. Plan both forms together.

4. A simple illustration

A manufacturer is reviewing its FY 2025-26 purchase invoices in November 2026 and finds three cases:

The finance manager says: "GSTR-9 is due only on 31 December, so we can decide on these invoices in December." That mixes up the two deadlines. By December, Invoice B's credit would be time-barred. And if the team files GSTR-9 on, say, 20 November, the ITC window would close on that date. This is a hypothetical illustration.

5. Other FY 2025-26 actions with the same 30 November date

• Credit notes (section 34(2)): credit notes for FY 2025-26 supplies must be declared by 30 November 2026 or the date of filing the annual return, whichever is earlier.
• GSTR-1 corrections (section 37(3)): errors or omissions in FY 2025-26 outward supply details can generally be rectified up to the same date.
• Filed GSTR-3B cannot be revised. Any omission has to be corrected through a later GSTR-3B within the time limits.

6. Action points for businesses

1. 1Do not file the FY 2025-26 annual return yet.Now
   Complete the ITC, credit note and GSTR-1 correction review first. Filing GSTR-9 before 30 November 2026 closes the window early.
2. 2Reconcile the purchase register with GSTR-2B.This week
   Run the full-year reconciliation and list credits not yet taken, with the reason for each.
3. 3Verify each unclaimed credit.This week
   Check the invoice, GSTR-2B, receipt of goods or services, payment and section 17(5). Claim only what is eligible.
4. 4Take eligible credit in a return filed by 30 November 2026.By 30 Nov
   For monthly filers, generally the October 2026 GSTR-3B. Do not leave it to the last day, in case of portal or payment issues.
5. 5Issue pending credit notes and GSTR-1 corrections.By 30 Nov
   Review year-end discounts, returns and rate or value errors for FY 2025-26 supplies.
6. 6Act on pending IMS records.This week
   Clear pending or rejected records relating to FY 2025-26 so that the credit position is clean.
7. 7Then prepare GSTR-9 and GSTR-9C together.December 2026
   Use audited or final accounts, reconcile turnover, tax and ITC, and file before 31 December 2026.

7. Action points for GST professionals

1. 1Send clients a 30 November reminder now.
   Cover ITC, credit notes and GSTR-1 corrections, and ask them not to file GSTR-9 before the review is complete.
2. 2Check QRMP clients separately.
   Confirm whether any FY 2025-26 credit can still be taken in a return filed by 30 November 2026.
3. 3Keep the cutoff and eligibility separate.
   Advise on each credit under sections 16 and 17 first; the time limit only decides when it can be taken.
4. 4Examine reclaims and special cases individually.
   Credits reversed earlier and reclaimable, and cases under sections 16(5) and 16(6), need specific examination.
5. 5Plan GSTR-9 and GSTR-9C as one filing.
   Late fee runs till both are filed where GSTR-9C is required.
6. 6Track the proposed amendments.
   Watch for the Council's recommended changes to sections 16, 37 and 39, but advise on the law as it stands.

8. Five-minute self-check

Ask your finance manager or GST professional to answer YES, NO or NOT SURE:

A NO or NOT SURE is a signal to review, not proof of non-compliance.

9. Documents to keep ready

• Purchase and expense registers for FY 2025-26, invoice-wise, with supplier GSTINs and tax amounts.
• GSTR-2B for each month and the IMS action history.
• Filed GSTR-3B returns with acknowledgements, showing ITC taken, reversed and reclaimed.
• Supplier invoices and debit notes supporting the credits selected.
• ITC eligibility working under sections 16 and 17.
• Turnover working at PAN level to decide the annual return requirement.
• Financial statements and GST reconciliation for GSTR-9 and GSTR-9C.
• Exception sheet listing eligible, ineligible and pending items, with the person responsible.

10. What if you find a problem?

11. Official sources

1. CGST Act, 2017: section 16 (including sub-sections (2), (4), (5) and (6)), section 17(5), section 34(2), section 37(3), section 44 and section 47(2).
2. CGST Rules, 2017: rule 80 (annual return and GSTR-9C).
3. Notification No. 15/2025-Central Tax dated 17 September 2025: exemption from filing the annual return for aggregate turnover up to Rs. 2 crore, FY 2024-25 onwards.
4. Circular No. 246/03/2025-GST dated 30 January 2025: complete annual return and late fee for delayed GSTR-9C.
5. GSTN advisory dated 13 October 2026: GSTR-9 and GSTR-9C for FY 2025-26 enabled on the portal.
6. Press release on the recommendations of the 57th GST Council meeting, 8 October 2026 (proposals only).

The Act, Rules, notifications and circulars are available on taxinformation.cbic.gov.in and cbic-gst.gov.in; advisories on gst.gov.in.

Scope of this article: the article explains the general time limits for FY 2025-26 as on the review date. No extension of the section 16(4) date or the annual return due date had been notified on that date. Individual records have not been examined.

GST DOST | GST Reconciliation, Annual Return and Professional Advisory