ITC on GSTR-9 and 9C – Case Study | Analysis | Compilation

Input Tax Credit (ITC) in GSTR-9 and 9C refers to the total eligible and ineligible credits relating to a financial year that a registered person must report, reconcile, and justify in the annual return (GSTR-9) and the reconciliation statement (GSTR-9C). It covers ITC availed, reversed, reclaimed, or pending based on GSTR-3B and GSTR-2B, and requires matching of books of accounts with auto-populated GST data.

Table of Contents

1. Case Study 1 – Analysing the Effect of Spillover Transactions w.r.t. ITC
2. Case Study 2 – Analysing the Effect of ITC – Availment, Reversal and Reclaim
3. Whether Standards on Auditing Can Be Applied on a Compilation Engagement Performed by a Professional for GSTR-9/9A and/or GSTR-9C Here?
4. Which Technical Standard Should be Applied for Performing the Assignment of Preparation of GSTR-9/9A and/or GSTR-9C?
5. Responsibility of Professional for Compilation Engagement
6. Agreeing to the Terms of Appointment
7. Responsibility of Management
8. Reliance to Be Placed by the Practitioner
9. Key Factors to Be Incorporated in the Report to Be Issued by the Practitioner
10. Format of Compilation Report

Check out Taxmann's GST Annual Return & Reconciliation which is an all-inclusive professional handbook for preparing and filing GSTR-9 and GSTR-9C under India's GST regime. Updated as per Notification No. 13/2025-CT dated 17th September 2025, it offers a 360° integration of law, accounting, audit, and procedural practices, ensuring accuracy, compliance, and audit readiness. Authored by Adv. Vivek Laddha, Dr Shailendra Saxena, and CA. Pooja Patwari, the book features amendment-driven analysis, 30+ case studies, 50+ FAQs, and practical checklists, supported by detailed financial linkages and stepwise filing guidance. It stands as an indispensable reference for GST professionals, corporates, and academicians seeking structured, error-free annual compliance.

Registered person has to be very cautious in declaration of ITC in GSTR-9 since department is using it as final summary for a particular FY. We have included 2 Case Studies based on amended position wherein first case study is for analysing the spillover transactions and second case study is for declaration of ITC – Availment, Reversal and Reclaim.

GST Network has issued FAQs on GSTR-9/9C for FY 2024-25 dated 16th October 2025 to guide that how annual return is to be prepared. Though this set of FAQs do not have any binding effect, still one may take a benefit of their guidance

1. Case Study 1 – Analysing the Effect of Spillover Transactions w.r.t. ITC

S. No.	Particulars	Amount	Remarks
Preparation of Tables 6, 7, 8, 12 and 13 of GSTR-9 of 2024-25 Step 1 – Collection of Facts in Below Manner
S. No.	Particulars	Amount	Remarks
0	ITC as per Books (Actual Eligible) of 2024-25	180
1	ITC reflected in GSTR-2B of FY 2024-25	175	Invoice dated from previous Year and Invoice dated from current year reflected in GSTR-2B of 2024-25
2	ITC availed as per GSTR-3B of FY 2024-25	175	S. No. (3+4+6)
3	ITC of 2023-24 reflected in GSTR-2B of 2024-25	20	ITC of Books reflected in GSTR-2B
4	ITC of 2024-25 reflected in GSTR-2B of 2024-25	150
5	ITC of 2024-25 reflected in GSTR-2B of 2025-26	30*
6	ITC of 2023-24 (Reflected in GSTR-2B of 2023-24) availed in GSTR-3B of 2024-25	5	Table 6A1 of GSTR-9
7	ITC of 2023-24 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2024-25	20	Table 6B of GSTR-9
8	ITC of 2024-25 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2024-25	150	Table 6B of GSTR-9
9	ITC of 2024-25 (Reflected in GSTR-2B of 2024-25) availed in GSTR-3B of 2025-26	5	Table 8C of GSTR-9
10	ITC of 2024-25 (Reflected in GSTR-2B of 2025-26) availed in GSTR-3B of 2025-26	30*	*No action

Step 2 – Details to Be Declared in GSTR-9 of the Case
S. No.	Particulars	Amount	Remarks
6A	Total amount of input tax credit availed through FORM GSTR-3B (Sum total of table 4A of FORM GSTR-3B)	175
6A1	*ITC of preceding financial year availed in the financial year (which is included in 6A above) other than ITC reclaimed under rule 37 and rule 37A	5
6A2	*Net ITC of the financial year =(A-A1)	170
6B	Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs)	170
6H	Amount of ITC reclaimed under the provisions of the Act
7	ITC Reversal
8A	ITC as per GSTR-2B (Tables 3 & 5 thereof)	175
8B	*ITC as per sum total 6(B) above	170
8C	ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next financial year upto specified period	5
8D	Difference [A-(B+C)]	0
12	*ITC of the financial year reversed in the next financial year
13	*ITC of the financial year availed in the next financial year	5

* Shows the amended tables of GSTR-9 of FY 2024-25 onwards.

2. Case Study 2 – Analysing the Effect of ITC – Availment, Reversal and Reclaim

Illustration of ITC Claim, Reversal and Reclaim (With Comparison Now and Then) with Amendment introduced in vide Notification No. 13/2025-CT, Dated 17-9-2025)

S. No.	Particulars	Table Positioning
Preparation of Tables 6, 7, 8 of GSTR-9 of 2024-25 Step 1 – Collection of Facts in Below Manner
S. No.	Particulars	Table Positioning
1	Reversal of ITC in CY	2024-25	2023-24
1.1	Reversal of ITC due to rule 37 or 37A
1.1.1	Reversal of ITC which was availed in PY	7A/7A1	7A/7H1
1.1.2	Reversal of ITC which is availed in CY	7A/7A1	7A/7H1
1.2	Reversal of ITC due to other than rule 37 or 37A
1.2.1	Reversal of ITC which was availed in PY
1.2.2	Reversal of ITC which is availed in CY
2	Reclaim of ITC in CY	2024-25	2023-24
2.1	Reclaim of ITC reversed due to rule 37 or 37A
2.1.1	Reclaim of ITC which was reversed in PY	6H	6H
2.1.2	Reclaim of ITC which is reversed in CY	6H	6H
2.2	Reclaim of ITC reversed due to other than rule 37 or 37A
2.2.1	Reclaim of ITC which was reversed in PY	6A1	6H
2.2.2	Reclaim of ITC which is reversed in CY	6H	6H

		Amount		Table Positioning
S. No.	Particulars	2024-25	2023-24	2024-25	2023-24
Step 2 – Details to Be Declared in GSTR-9 of the Case
		Amount		Table Positioning
S. No.	Particulars	2024-25	2023-24	2024-25	2023-24
0.1	ITC as per GSTR-2B of 2024-25	800	1000
0.2	ITC reflected in GSTR-2B of 2023-24 but availed in 2024-25	0
0.3	ITC reflected in GSTR 2B of 2024-25 but availed in 2025-26	0
1	Gross ITC Availed in GSTR 3B in 2024-25	1000	1200	6A	6A
1.1	ITC Fresh claim in 2024-25	800	1000	6B	6B
2	Reversal of ITC in FY 2024-25	350	550
2.1	Reversal of ITC due to rule 37 or 37A	200	400
2.1.1	Reversal of ITC which was availed in 2023-24	70	270	7A/7A1	7A/7H1
2.1.2	Reversal of ITC which is availed in 2024-25	130	130	7A/7A1	7A/7H1
2.2	Reversal of ITC due to other than rule 37 or 37A	150	350
2.2.1	Reversal of ITC which was availed in 2023-24	40	240	7H1	7H1
2.2.2	Reversal of ITC which is availed in 2024-25	110	110	7H1	7H1
		0	200
3	Reclaim of ITC in FY 2024-25	200	400
3.1	Reclaim of ITC reversed due to rule 37 or 37A	120	320
3.1.1	Reclaim of ITC which was reversed in 2023-24	70	270	6H	6H
3.1.2	Reclaim of ITC which is reversed in 2024-25	50	50	6H	6H
3.2	Reclaim of ITC reversed due to other than rule 37 or 37A	80	280
3.2.1	Reclaim of ITC which was reversed in 2023-24	20	220	6A1	6H
3.2.2	Reclaim of ITC which is reversed in 2024-25	60	60	6H	6H
6A	Total amount of input tax credit availed through FORM GSTR-3B (Sum total of table 4A of FORM GSTR-3B)	1000	1200
6A1	*ITC of preceding financial year availed in the financial year (which is included in 6A above) other than ITC reclaimed under rule 37 and rule 37A	20	220
6A2	*Net ITC of the financial year = (A-A1)	980	980
6B	Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs)	800	1000
6H	Amount of ITC reclaimed under the provisions of the Act	180	380
7	ITC Reversal	350	750
		630	630
8A	ITC as per GSTR-2B (Tables 3 & 5 thereof)	800	1000
8B	*ITC as per sum total 6B above (Note- FY 2024-25 onwards it is just an auto-populated data of table 6B; for GSTR-9 of preceding FYs, it was the sum total of 6B and 6H)	800	1000
8C	ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next financial year upto specified period	0	0
8D	Difference [A-(B+C)]	0	0
12	*ITC of the financial year reversed in the next financial year	0	0
13	*ITC of the financial year availed in the next financial year	0	0

* Shows the amended tables of GSTR-9 of FY 2024-25 onwards.

Even after the omission of the GST Audit Provision u/s 35(5), still the role of a professional exists. In case where a professional is requested to compile the annual return and reconciliation statement, professional is required to adhere with the set of principles. For the sake of discussion to understand the role and responsibilities of management and professional, we are referring to the provisions of CA Act and Engagement and Quality Control Standards. It may be noted that the professional is not required to perform attestation services as requirement of GST audit does not remain in existence w.e.f. FY 2020-21. So, the issue arises whether a professional has to follow the standard prescribing any set of procedures. Before understanding the applicability of standard for the assignment supposed to be performed by a CA, it is pertinent to refer the provision of CA Act, 1949. As per clause (7) of the Second Schedule of CA Act, A chartered accountant in practice shall be deemed to be guilty of professional misconduct, if he does not exercise due diligence, or is grossly negligent in the conduct of his professional duties. (Kindly note that on similar lines, the provisions are there for Company Secretary and Cost Accountants in CS Act and CWA Act respectively.) Volume II of Code of Ethics issued by ICAI states that in discharging his professional responsibilities it is expected that a Chartered Accountant would exercise a reasonable degree of diligence in his professional assignment. This would imply that a member in practice keeps himself updated of the changes and developments in the professional space that could have an impact on his professional assignments. The member should also act diligently in accordance with applicable technical and professional standards. It is stated that standards drafted by ICAI are not applicable for other professionals but one can take the advantage of the reading of those standards.

3. Whether Standards on Auditing Can Be Applied on a Compilation Engagement Performed by a Professional for GSTR-9/9A and/or GSTR-9C Here?

It is not required to perform attestation services on compilation engagement
performed by professional for GSTR-9/9A and/or GSTR-9C and therefore it is clear that this assignment does not require to provide any assurance services. In the opinion of authors, neither Standards on Auditing (SA) nor the Standards on Review Engagements (SRE) can be applied in the situation where the entity requests the CA to prepare the GSTR-9/9A and/or GSTR-9C. (Conclusion does not end here so read the text written in next para)

4. Which Technical Standard Should be Applied for Performing the Assignment of Preparation of GSTR-9/9A and/or GSTR-9C?

In the opinion of the authors, SRS-4410, i.e. Compilation Engagement should be referred which prescribes the set of procedures and responsibility of management and professional.

Meaning of Compilation Engagement

As per Para 17 of SRS-4410, Compilation engagement means an engagement in which a practitioner applies accounting and financial reporting expertise to assist management in the preparation and presentation of financial information of an entity in accordance with an applicable financial reporting framework (defined below), and reports as required by this SRS.

Applicable financial reporting framework means the financial reporting framework adopted by management and, where appropriate, those charged with governance in the preparation of the financial information that is acceptable in view of the nature of the entity and the objective of the financial information, or that is required by law or regulation.

Preparation of GSTR-9/9A and/or GSTR-9C is satisfying the conditions of the definition of ‘Compilation Engagement’ because:

(a) Preparation of GSTR-9/9A and/or GSTR-9C an engagement in which a practitioner applies accounting and financial reporting expertise to assist management in the preparation and presentation of financial information of an entity.

(b) GSTR-9/9A and/or GSTR-9C, being requirement of the law is an applicable financial reporting framework.

5. Responsibility of Professional for Compilation Engagement

Professional shall take responsibility for:

(a) The overall quality of each compilation engagement to which he is assigned; and

(b) The engagement being performed in accordance with the firm’s quality control policies and procedures:

(i) appropriate procedures regarding the acceptance and continuance of client relationships and engagements;

(ii) Being satisfied that the engagement team collectively has the appropriate competence and capabilities to perform the compilation engagement;

(iii) Being alert for indications of non-compliance by members of the engagement team with relevant ethical requirements, and determining the appropriate action if matters come to the professional’s attention indicating that members of the engagement team have not complied with relevant ethical requirements;

(iv) Directing, supervising and performing the engagement in compliance with professional standards and applicable legal and regulatory requirements; and

(v) Taking responsibility for appropriate engagement documentation being maintained.

6. Agreeing to the Terms of Appointment

Under this SRS, the practitioner is required to obtain the agreement of management, or where applicable those charged with governance, on management’s responsibilities in relation to both the financial information and the compilation engagement as a condition precedent to accepting the engagement.

In smaller entities, management, or those charged with governance where applicable, may not be well-informed about what those responsibilities are, including those arising in applicable law or regulation. In order to obtain management’s agreement on an informed basis, the practitioner may find it necessary to discuss those responsibilities with management in advance of seeking management’s agreement on its responsibilities.

If management does not acknowledge its responsibilities in the context of a compilation engagement, the practitioner is not able to undertake the engagement, and it is not appropriate for the practitioner to accept the engagement unless required to do so under applicable law or regulation. In circumstances where the practitioner is nevertheless required to accept the engagement, the practitioner may need to communicate with management about the importance of these matters and the implications for the engagement.

7. Responsibility of Management

The compilation engagement to be performed is conducted on the basis that you acknowledge and understand that our role is to assist you in the preparation and presentation of the financial statements in accordance with the financial reporting framework you have adopted for the financial statements. Accordingly, you have the following overall responsibilities that are fundamental to our undertaking the compilation engagement in accordance with SRS 4410 (Revised):

(a) Responsibility for the financial statements and the preparation and presentation thereof in accordance with a financial reporting framework that is acceptable in view of the intended use of the financial statements and the intended users.

(b) Responsibility for the design, implementation and maintenance of such internal control as you determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

(c) Responsibility for the accuracy and completeness of the records, documents, explanations and other information you provide to us for the purpose of compiling the financial statements.

(d) Responsibility for the judgments needed in the preparation and presentation of the financial statements, including those for which we may provide assistance in the course of the compilation engagement.

8. Reliance to Be Placed by the Practitioner

The practitioner is entitled to rely on management to provide all relevant information for the compilation engagement on an accurate, complete and timely basis. The form of the information provided by management for the purpose of the engagement will vary in different engagement circumstances. In broad terms, it will comprise records, documents, explanations and other information relevant to the compilation of the financial information using the applicable financial reporting framework. The information provided may include, for example, information about management assumptions, intentions or plans underlying development of accounting estimates needed to compile the information under the applicable financial reporting framework.

9. Key Factors to Be Incorporated in the Report to Be Issued by the Practitioner

• Financial information prepared for a special purpose, i.e., to comply with financial reporting requirements established by a regulator, in accordance with provisions established by the regulator prescribing the form and content of the financial information.
• The applicable financial reporting framework is a compliance framework.
• The financial information is intended to meet the needs of particular users, and use of the financial information is restricted to those users.
• Distribution of the practitioner’s report is restricted to the intended users.

10. Format of Compilation Report

[To the Management of ABC Company]

We have compiled the accompanying schedule of [identify the compiled financial information] of ABC Company as at March 31, 20XX (“the Schedule”) based on information you have provided.

We performed this compilation engagement in accordance with Standard on Related Services 4410 (Revised), Compilation Engagements.

We have applied our expertise in accounting and financial reporting to assist you in the preparation and presentation of the Schedule as prescribed by [insert name of or reference to the relevant regulation]. We have complied with relevant ethical requirements.

This Schedule and the accuracy and completeness of the information used to compile it are your responsibility.

Since a compilation engagement is not an assurance engagement, we are not required to verify the accuracy or completeness of the information you provided to us to compile the Schedule. Accordingly, we do not express an audit opinion or a review conclusion on whether the Schedule is prepared in accordance with [insert name of or reference to applicable financial reporting framework as specified in the relevant regulation].

As stated in Note X, the Schedule is prepared and presented on the basis prescribed by [insert name of or reference to the applicable financial reporting framework as specified in the relevant regulation], for the purpose of ABC Company’s compliance with [insert name of or reference to the relevant regulation] Accordingly, the Schedule is for use only in connection with that purpose and may not be suitable for any other purpose.

Our compilation report is intended solely for the use of ABC Company and Regulator F, and should not be distributed to parties other than ABC Company or Regulator F.

For XYZ and Co.

Chartered Accountants

Firm’s Registration Number

Signature

(Name of the Member Signing the Compilation Report)

(Designation)

Membership Number