The Central Board of Direct Taxes (CBDT) has announced new due dates for filing GSTR-9 for the financial year 2025-26, along with a clear distinction between mandatory and optional tables. For small businesses, understanding these changes is crucial to stay compliant and avoid penalties.
What changed: new filing deadline and table classification
Earlier, the deadline for filing GSTR-9 for FY 2025-26 was aligned with the usual 31 December 2026 cut-off. The latest CBDT circular shifts the final filing date to 31 January 2027, giving taxpayers an extra month to complete the return. The same circular also categorises the tables in GSTR-9 into two groups – mandatory and optional – for the first time since the form’s introduction.
Mandatory tables must be filled irrespective of the taxpayer’s turnover or GST registration type. Optional tables can be left blank if they are not applicable, but the taxpayer must still indicate “Not Applicable” (N/A) in the designated field. Failure to follow this classification can trigger a penalty for non-compliance.
Who is affected: small businesses and composition taxpayers
The updated deadline applies to all regular taxpayers who are required to file GSTR-9, including small manufacturers, traders and service providers whose aggregate turnover is below the GST registration threshold but who have voluntarily registered. Composition scheme dealers, however, continue to file GSTR-4 and are not required to file GSTR-9.
For small businesses that file GSTR-9 annually for the first time, the new timeline offers a practical benefit: more time to reconcile the year-end data from GSTR-1, GSTR-3B and the GST portal. It also reduces the rush that often leads to errors in the mandatory tables.
What it means in practice: a simple worked example
Consider a small retailer, “ABC Stores”, with a turnover of ₹45 lakhs in FY 2025-26. The retailer filed monthly GSTR-1 and quarterly GSTR-3B on time. At year-end, the total outward supplies (taxable) recorded in GSTR-1 amount to ₹50 lakhs, and the total input tax credit (ITC) claimed in GSTR-3B is ₹6 lakhs.
When preparing GSTR-9, ABC Stores must fill the mandatory tables – for example, Table A (summary of outward supplies) and Table B (summary of inward supplies). Using the figures above, Table A will show ₹50 lakhs of outward supplies, while Table B will reflect the ₹6 lakhs of ITC. The optional tables, such as Table C (details of advances received) and Table D (details of advances paid), can be marked N/A because the retailer did not receive or pay any advances during the year. By correctly marking N/A, ABC Stores avoids the penalty that would arise from leaving those fields blank.
What to do and by when: step-by-step checklist
- Gather year-end data: Download the annual GSTR-1 summary and the GSTR-3B summary from the GST portal by 15 January 2027.
- Reconcile figures: Verify that the total outward supplies in GSTR-1 match the sales ledger, and that the ITC claimed matches purchase invoices.
- Identify mandatory tables: Refer to the CBDT circular – mandatory tables include Table A (outward supplies), Table B (inward supplies), Table E (tax payable), and Table F (tax paid).
- Mark optional tables: For any table that does not apply, enter “N/A” in the prescribed field rather than leaving it blank.
- Prepare the return: Use the GST portal’s GSTR-9 preparation tool or a certified GST software that incorporates the new validation rules.
- File by 31 January 2027: Submit the completed GSTR-9 and, if applicable, GSTR-9C (reconciliation) before the deadline.
- Retain documentation: Keep copies of the return, supporting invoices and reconciliation statements for at least six years.
Common mistakes and how to avoid them
Leaving optional tables blank – The portal now validates that every optional table must contain either data or the literal “N/A”. A blank field triggers an automatic rejection and may attract a penalty of ₹10,000 per non-compliant return.
Mismatching figures between GSTR-1 and GSTR-3B – Discrepancies often arise from delayed filing of GSTR-1 for late sales. Reconcile before the 15 January cut-off to avoid last-minute corrections.
Missing the extended deadline – While the deadline has been extended to 31 January 2027, the portal will lock the filing window on 1 February 2027. Late filing after this date attracts a penalty of 0.5% of the tax payable per day, subject to a maximum of 100% of the tax amount.
Incorrect use of “N/A” – The entry must be in uppercase letters without extra spaces. Using “na” or “Not Applicable” leads to validation errors.
Summary of mandatory vs optional tables (as per CBDT circular)
| Table | Purpose | Classification |
|---|---|---|
| Table A | Summary of outward supplies | Mandatory |
| Table B | Summary of inward supplies | Mandatory |
| Table C | Advances received | Optional |
| Table D | Advances paid | Optional |
| Table E | Tax payable | Mandatory |
| Table F | Tax paid | Mandatory |
Frequently asked questions
Can I file GSTR-9 after 31 January 2027?
No. The filing window closes on 1 February 2027. Any return submitted after that date will be treated as a belated filing and will attract the standard penalty for late filing.
Do composition scheme dealers need to file GSTR-9?
No. Composition dealers continue to file GSTR-4. The GSTR-9 requirement applies only to regular taxpayers, including those who have voluntarily registered despite low turnover.
What if I mistakenly left an optional table blank?
The portal will reject the return during validation. You will need to edit the return, enter “N/A” in the blank field, and re-submit before the deadline to avoid the ₹10,000 penalty.
Is there any relief for small taxpayers who missed the deadline due to technical glitches?
The CBDT has allowed a one-time grace period of five days for technical failures, provided the taxpayer raises a ticket on the GST portal before the original deadline. The grace period does not waive penalties for substantive errors, only for the filing delay caused by system downtime.
Sources
- GST portal
- CBIC GST
- GSTR-9 Due Date For FY 2025-26: Latest Update — CAclubindia
- GSTR-9 and 9C Optional vs Mandatory Tables FY 2025-26: Complete Compliance Guide — CAclubindia
Reviewed: November 2026. Tax rules change — verify the current financial year and assessment year before you rely on any figure.
This is general educational information for Indian taxpayers, not personalised tax, legal or financial advice. Union of Taxpayers is an independent platform and not a government body. Consider a qualified professional for your specific situation.
Not professional advice
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