Filing of GSTR-9 and GSTR-9C for FY 2024-25 is now available on the GST Portal

✅ Recent Update

GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2024-25 are now available on the GST Portal.

Taxpayers can now file their annual returns and reconciliation statements in line with the updated formats and instructions, which reflect the recent amendments in GST rules and legislation.

The deadline to file both forms, unless an extension is announced, is 31st December 2025.

🆕 GSTR-9 & 9C: Key Modifications for FY 2024-25

The revised forms include multiple updates based on recent amendments and notifications. Let’s go through them step by step:

 

1️⃣ Enhanced ITC Reporting and Reversal Requirements

  • Taxpayers are now required to submit more detailed information regarding Input Tax Credit (ITC).
  • Reversals must be reported separately as per Rules 37, 37A, 38, 42, and 43.

This is intended to enhance reconciliation accuracy and ensure proper tracking of ITC.
👉 Tip: Before submitting, thoroughly check reversal entries, reclaimed credits, and auto-filled data.

2️⃣ New Fields for Import and Transitional Credit Reporting

  • New fields have been introduced for reporting import-related ITC and transitional credits.
  • This promotes greater transparency for businesses importing goods or transferring credits from previous tax regimes.
    👉 Tip: Match your import details with the ICEGATE system and verify accuracy before submission.

3️⃣ Auto-Population of Data and Mismatch Handling

  • The updated forms automatically fetch data from GSTR-1, GSTR-3B, and GSTR-2B.

Several fields will be prefilled to minimize manual mistakes.
However, taxpayers should carefully verify and reconcile all details, as discrepancies may trigger future audits.

👉 Tip: Ensure sales, ITC, and outward supply figures are fully reconciled before filing.

4️⃣Late Fee and Interest Reporting Standardized

  • The revised guidelines mandate clear disclosure of any late fees or interest due under Section 47(2).
  • All filing delays must be reported transparently in the prescribed form.

👉 Tip: Do not use back-dated entries — ensure the actual delay period and corresponding charges are reported accurately.

5️⃣New Instructions with Relevant Rule References

  • The instructions for both GSTR-9 and GSTR-9C have been revised to enhance clarity and ease of understanding.
  • Table references and compliance logic have been simplified to minimize errors in interpretation

👉 Tip: Review the updated instruction sheet before beginning the filing process.

 

Key GST update on GSTR-2B and IMS modifications effective from 1st October 2025

Amidst multiple misleading social media posts regarding significant changes to the GST return system from 1st October 2025, the Goods and Services Tax Network (GSTN) has released a key clarification.
This advisory seeks to clear up confusion about the Invoice Management System (IMS) and its effects on GSTR-2B, GSTR-3B, and the auto-population of Input Tax Credit (ITC)

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📌 1️⃣No Modifications to ITC Auto-Population

GSTN has clearly stated that there is no change in the auto-population of Input Tax Credit (ITC) in GST returns.

The process of auto-populating ITC from GSTR-2B to GSTR-3B will function as it always has.
ITC will continue to be auto-filled based on the invoices uploaded by suppliers in their GSTR-1 filings.
The introduction of the Invoice Management System (IMS) does not impact this auto-population process.

👉 In summary: Taxpayers are not required to manually import ITC data — the system will continue fetching it automatically.

📌 2️⃣GSTR-2B Continues to be Auto-Generated Without Manual Input

GSTN has clarified that GSTR-2B will continue to be auto-generated on the 14th of every month, as is currently the case.

There is no need for taxpayers to manually create or trigger GSTR-2B through the Invoice Management System (IMS).
GSTR-2B will remain an auto-drafted statement, reflecting both eligible and ineligible Input Tax Credit (ITC) based on supplier GSTR-1 filings.

That said, the new IMS will provide taxpayers with enhanced flexibility to manage their invoice data.

🧾 Key actions available in IMS:

  • Accept invoices or mark them as pending

  • Act on credit notes

  • View the reconciliation summary

Even after GSTR-2B is generated, taxpayers can continue to take these actions in IMS until GSTR-3B is filed.
If any updates are made — such as accepting or rejecting invoices or credit notes — GSTR-2B can be regenerated accordingly before submission.

👉 Bottom line: The ITC mechanism remains unchanged, but IMS offers greater control and transparency in handling return data.

📌 3️⃣ New Options for Credit Note Handling Effective October 2025

A major enhancement in Credit Note management will take effect with the introduction of the IMS from the October 2025 tax period.

🧾 Key Highlights:

Greater Control for Recipients:
Recipients will now have the option to keep a credit note or related document in a pending state, rather than being required to act on it immediately.

Flexible ITC Reversal:
Upon accepting a credit note, recipients can choose to reverse Input Tax Credit (ITC) only to the extent that it was actually availed.
This allows for manual adjustment, giving taxpayers more control and precision in calculating ITC.

Purpose of the Change:
This flexibility ensures that recipients don’t have to reverse the entire ITC if only a partial credit was claimed initially.
It helps avoid unnecessary credit loss and better reflects real-world business transactions.

💡 Implications for Taxpayers

✅ No additional effort needed — ITC auto-population and GSTR-2B generation continue unchanged.
✅ Increased flexibility — taxpayers can manage invoices and credit notes in IMS even after GSTR-2B is generated.
✅ Precise credit reversal — recipients can partially reverse ITC based on the actual amount availed.
✅ IMS enhances transparency without adding complexity to the filing process.

⚙️ Practical Example

Scenario:
You claimed an Input Tax Credit (ITC) of ₹8,000 on an invoice, but later the supplier issued a credit note for ₹2,000.
Previously, there was uncertainty about whether you needed to reverse the entire amount.

Starting October 2025 under IMS:

  • You can accept the credit note, and

  • Reverse ITC only proportional to the ₹8,000 actually availed — not the full invoice amount.

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📢 Essential Insights

  • The ITC auto-population process remains unchanged.

  • GSTR-2B will continue to be auto-generated on the 14th of each month.

  • IMS introduces flexibility to review, adjust, and regenerate ITC details before filing GSTR-3B.

  • Credit Note management is enhanced — enabling proportionate ITC reversal and the option to keep notes pending.

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🧮 In Conclusion

The GSTN’s latest advisory reassures taxpayers that the core GST return filing process remains the same, despite IMS integration.
IMS is designed to make the process smarter, not harder — by allowing flexibility and transparency in invoice and ITC management.

Taxpayers are advised to continue filing their returns as usual and use the IMS dashboard for better control and reconciliation.

In summary:

“IMS is not a replacement for GST returns — it’s a smarter way to manage them.”

Updated GST Refund Mechanism to Roll Out from October 2025

Instruction No. 06/2025-GST

In the 56th GST Council Meeting (3 Sept 2025), it was decided that refund processing should be risk-based and system-driven, to speed up genuine cases and flag risky ones.

  • Accordingly, Rule 91(2) of CGST Rules 2017 was amended (via Notification 13/2025-CT dated 17 Sept 2025).
  • From now, 90% of refund can be sanctioned provisionally if the case is low-risk as per system evaluation.

New Rule 91(2) — Provisional Refund based on Risk Score

  • The GST system will automatically classify refund applications as “Low Risk” or “High Risk.”
  • For Low-Risk cases:
    • 90% of the claimed refund will be released provisionally by the officer.
    • No detailed scrutiny required before provisional sanction.
  • For High-Risk cases:
    • Refund will not be sanctioned provisionally.
    • The officer will carry out detailed verification as per Rule 92.

Officer’s Discretion — When Refund Can Be Withheld

Even if a refund is marked low-risk, the proper officer may decide not to issue provisional refund in specific cases, but he must:

  • Record written reasons, and
  • Proceed for detailed scrutiny under Rule 92.

📌 Examples:

  • Past refund issues pending in appeal,
  • Previous SCN issued,
  • Cases under prosecution or fraud detection, etc.

Non-Eligible Persons under Section 54(6)

As per Notification 14/2025-CT (17 Sept 2025), certain categories of taxpayers cannot get provisional refund for zero-rated supplies (exporters).
Also, those under prosecution in last 5 years for evasion > ₹2.5 crore are not eligible for provisional refund.

Systemic Restrictions

  • Once provisional refund is sanctioned, it cannot be adjusted or withheld for any demand or recovery under Section 54(10)/(11).
  • If a case has any pending demand or SCN, officer should process refund on final basis instead of provisional.
  • Provisional refund must be avoided where earlier refund matter is sub-judice or under dispute.

Trade Facilitation — Use of Discretion Sparingly

  • The new system is meant to facilitate trade, not to delay refunds.
  • Therefore, the proviso to Rule 91(2) (officer’s power to deny provisional refund) must be used rarely and only with strong justification, not just for routine scrutiny.

Excess Provisional Refund — Recovery Mechanism

  • If after final scrutiny it’s found that excess refund was given provisionally,
    the officer will issue FORM GST RFD-08 (Show Cause Notice) under Section 54 read with Section 73 / 74 / 74A to recover the excess.

Applicability Date

  • Risk-based provisional refund applies to all refund applications filed on or after 1 October 2025.

Extension to Inverted Duty Refunds (IDS)

  • Earlier, 90% provisional refund was only for zero-rated supplies (exports).
  • Now, GST Council recommended to extend this to Inverted Duty Structure (IDS) refunds too.
  • Formal amendment to Section 54(6) will take time (via next Finance Act + State amendments).
  • So, as interim trade facilitation, the Centre allowed 90% provisional refund for IDS cases filed on or after 1 Oct 2025—same process as exports.

Processing Flow (Para 3.1 to 3.4)

Step-wise:

  1. Refund application filed (RFD-01).
  2. Officer issues Acknowledgment RFD-02 or Deficiency Memo RFD-03 within prescribed timeline.
  3. If marked Low Risk → officer issues Provisional Refund = 90%.
  4. If High Risk → detailed scrutiny → final refund only after full examination.
  5. System will guide officer based on risk score from analytics module.

Supervision & Monitoring

  • Commissioners will supervise proper implementation.
  • Chief Commissioners must ensure that these trade facilitation measures are followed in letter and spirit.
  • Feedback / implementation difficulties to be reported to CBIC GST Policy Wing.

Key Takeaways for Taxpayers / Exporters / CA Professionals

  • ⏱ Faster Refunds for low-risk and compliant taxpayers.
  • 🧾 Automated Risk Score – keep returns accurate, timely and consistent to stay in low-risk category.
  • ⚠️ No Provisional Refund if prosecution, pending SCN or appeal.
  • 📋 IDS Refunds also eligible for 90% provisional refund (temporary relief).
  • 🧠 Officers’ discretion limited – must record reasons if they hold back refund.
  • 🧮 Check refund history before filing — pending cases may affect risk score.
⚠️ Beyond the Investment: What Startup Fundraising Really Costs You

The Real Price of Raising Capital for Startups

Securing capital marks a defining milestone in every startup’s growth path. While attention often gravitates toward the headline valuation and total funds raised, it’s equally important to understand the actual cost of reaching that milestone.

Recognising these expenses isn’t merely about accounting accuracy — it’s about empowering founders to make informed financial and strategic choices.

Each phase of fundraising comes with its own financial commitments, and these must be anticipated well in advance. The reality is that many of these costs are borne by the startup, whether or not the deal eventually materialises. Proper planning helps safeguard liquidity and ensures the company remains financially stable throughout the fundraising journey.

Key Insight

Raising money can be expensive — and if unmanaged, these costs can quietly consume a notable portion of the very funds you aim to secure.

Expenses such as advisory retainers, legal and diligence fees, marketing costs, and months of lost operating focus can add up quickly. Without careful management, these can strain working capital and delay business progress.

Startup Fundraising Expenses

So, what exactly should founders plan and budget for? Let’s break it down.

1. Upfront Advisory Fees and Retainers

The first expense comes from hiring external experts — placement agents, venture advisors, or fundraising consultants. These professionals often charge monthly retainers to structure your raise, prepare materials, and coordinate investor outreach.

As of 2025, retainers generally range between £2,000 and £10,000 per month, lasting up to a year for larger rounds. Additionally, one-time engagement fees of 2%–5% of the fundraising target are often included.

💡 Tip: Always request a clear deliverables list — such as investor meetings or valuation reports — tied directly to any advance payments. Transparency ensures accountability and value.

2. Success Fees or Commissions

Nearly all intermediaries charge a success-based commission, usually between 3%–7% of total funds raised. On a £1 million round, a 5% fee means £50,000 payable upon closing.

Check whether the commission applies to gross commitments or the net received after deductions, and confirm whether it’s due on signing or on fund transfer.

3. Legal & Advisory Costs

Legal counsel is essential for drafting, reviewing, and negotiating term sheets. Expect to spend between £5,000 and £20,000 depending on deal complexity.

In some cases, investors may ask startups to cover a portion of their legal expenses — adding another £10,000 to £30,000. While cutting corners may seem tempting, solid legal advice protects against future liabilities.

4. Due Diligence Expenses

Investors conduct due diligence covering financial audits, IP verification, and compliance checks. While investors lead the process, startups often pay for supporting reports — ranging from £2,000 to £10,000.

Typical reimbursable costs include accounting verification, IP audits, and secure data room setup for document sharing.

5. Marketing & Investor Material Costs

A strong pitch requires professional storytelling. External support for pitch decks, videos, and financial models can cost:

  • Deck design: £1,000–£5,000

  • Investor video: £2,000–£10,000

  • Financial modelling: £1,000–£5,000

Though optional, polished materials can increase investor engagement by 20–30%.

6. Travel & Investor Meetings

Despite digital tools, many investors prefer in-person meetings. Factor in £1,000–£5,000 for travel, accommodation, and event participation.

7. Time & Opportunity Costs

Fundraising can take 3–9 months — time the founder could otherwise spend on customers or product development. This hidden cost often outweighs direct expenses and must be acknowledged in strategic planning.

8. Post-Funding Obligations

Even after funding closes, administrative and investor management costs persist — such as board meetings, statutory filings, and audit requirements. These recurring commitments should be part of your long-term forecast.

Budgeting Smartly for Fundraising

  • List every cost: Treat fundraising as its own project with a detailed budget.

  • Demand transparency: Get written confirmation of all fees and conditions from intermediaries.

  • Negotiate structure: See if retainers can be adjusted against final fees or legal costs capped.

  • Add a buffer: Always include a 10–20% contingency for unforeseen expenses.

Key GST Changes from October 2025 You Should Know | Returns, Credit Notes, IMS & Notices

Several important changes to the GST return ecosystem have been introduced recently and brought live on the GST portal. Together they tighten compliance, increase reliance on system-generated data and the Invoice Management System (IMS), and reduce the scope for late/retroactive corrections. Below is a practical explainer of each change, its implications, and an easy checklist of actions.

 

1) Pending GST returns older than 3 years will be blocked on the portal

GSTN has implemented the statutory three-year bar which prevents filing of GST returns beyond three years from their original due date. This enforcement is being rolled out by tax period and taxpayers are being advised that returns older than three years will become non-fileable on the portal once the validation is active for that tax period. In short: if a return’s due date is more than three years in the past, you will not be able to file it on GSTN once the bar is applied for that tax period.

2) Check your GST portal notices:

Tax authorities are active on older years. In particular, the last date for issuing notices under Section 73 (for certain past years) and Section 74 (for other years involving fraud/intentional evasion) is approaching/has been highlighted for specific years — meaning taxpayers should check portal notices immediately and respond where required. If you have not checked notices for FY 2021-22 (Section 73) or FY 2019-20 (Section 74), you may already have pending show-cause action that requires attention.

 

Check our GST Notice course

3) GSTR-1 → GSTR-3B link tightened: auto-populated 3B / non-editable fields

GSTN has further locked down the relationship between outward supplies reported in GSTR-1 and the summary liabilities reported in GSTR-3B. Values auto-populated from supplier filings will populate GSTR-3B and, for many tables, the taxpayer will not be able to edit those auto-populated figures directly in 3B. Corrections will have to be made via the supplier’s subsequent amendments (or through the prescribed amendment flow), not by free edits in the return. This step is intended to reduce manipulations and mismatches

Practical impact: Buyers must ensure their suppliers file GSTR-1 accurately and on time because once the data feeds into 3B it will be locked. Any mismatch will take longer to correct and could delay or deny ITC until corrected by the supplier.

4) GSTR-2B / IMS: GSTR-2B is now a taxpayer-generated statement via IMS — IMS is central to claiming ITC

The traditional notion of an “auto-generated” GSTR-2B statement is changing: taxpayers will rely more on the Invoice Management System (IMS) to generate and manage the ITC-relevant draft, perform matching, accept/reject invoices, and recompute the ITC position. The IMS now provides a controlled workflow — taxpayers can regenerate GSTR-2B-like reports based on actions taken in IMS rather than passively waiting for a portal report. Because of this, IMS records and actions (accept/reject/mark pending/enter ITC availed) are becoming the authoritative source for ITC claims and reconciliations.

Practical impact: Maintain disciplined IMS practices: reconcile invoices, accept only genuine supplies, and keep IMS comments/evidence. IMS snapshots may become crucial evidence during assessments.

5) Credit notes — recipient reversal of ITC now mandatory in proportion; IMS changes to assist reversal

Where suppliers issue credit notes that reduce taxable value or tax, recipients who have already availed ITC on the original invoice are required to reverse the ITC to the extent it was availed (i.e., reversal only to the extent of ITC actually used; if no ITC was taken, no reversal is needed). IMS has been enhanced to allow recipients to declare the exact ITC availed and reverse only that portion — and suppliers and recipients must coordinate via IMS actions. IMS will reflect amended credit note data and recompute recipients’ ITC accordingly.

Practical impact: Recipients must (a) track ITC availed at invoice level, (b) be ready to reverse only the utilized portion when a credit note is issued, and (c) act promptly on IMS notifications to avoid wrong ITC balances.

6) GSTR-7 (TDS Return) now requires invoice-wise reporting

Form GSTR-7 (the return for tax deductors under TDS provisions of GST) has been updated to require invoice-levelreporting rather than summarized figures. The GSTN portal has enabled invoice-wise filing functionality for GSTR-7 and deductors should prepare invoice-level TDS details for the relevant tax periods. This increase in granularity is meant to improve reconciliation between deductors and suppliers.

Practical impact: TDS deductors (platforms, government departments, etc.) must ensure their systems can provide invoice-level TDS details. Manual or summary reporting is no longer adequate.

Other system & procedural changes you should note

  • Non-editable auto-populated fields in 3B: The move to auto-populate and lock certain tables in GSTR-3B (from supplier GSTR-1 data) increases the importance of first-time accuracy.
  • IMS recordability: IMS now supports comments, pending flags, and better audit trail — use these features to create a defensible record.
  • Partial ITC reversal treatment: If only part of ITC was used, reversal is limited to that used portion; if no ITC was taken on that invoice, no reversal required. This is reflected in IMS logic.

What this means for taxpayers — practical scenarios

Scenario A — You are a buyer who claimed full ITC and supplier issues a credit note later:
You must reverse the ITC equal to the amount you actually availed (not necessarily the full ITC on the invoice) via IMS actions so your GSTR-2B/GSTR-3B position is correct.

Scenario B — You are a supplier and you issued corrected invoices/credit notes:
Your liability reduces in your outward returns, but unless the recipient acts on IMS, their ITC position might not get adjusted automatically. Coordinate via IMS and ensure records are synced.

 

Scenario C — You rely on old, delayed filings to fix mismatches:
With the three-year bar live, you cannot indefinitely rely on belated filings. If certain historical returns become barred, unresolved mismatches may remain and can trigger notices.

Checklist: Immediate steps for businesses & professionals

  1. Reconcile urgently: Reconcile GSTR-1 vs books vs buyer acknowledgements and clear pending mismatches via supplier follow-ups and IMS actions.
  2. Check GST portal notices: Regularly review notices for FY 2019-20 and FY 2021-22 periods, and respond promptly where required.
  3. Use IMS actively: Accept/reject invoices, record ITC availed at invoice level, and keep a log of IMS actions for audit trail.
  4. Prepare for locked 3B fields: Do not rely on being able to edit 3B later — ensure GSTR-1 accuracy and preserve proof of reconciliations.
  5. Plan for credit-note reversals: Track how much ITC you actually used for each invoice; be ready to reverse accordingly.
  6. For TDS deductors (GSTR-7): Ready your systems to capture invoice-level details; review past months’ records to avoid omission.