GSTR-9 FY 2024-25: Split the Credit, Cut the Noise - How the New Table 6 Can Save You a Notice

The annual return season has arrived with a genuinely useful upgrade. For FY 2024-25, GSTR-9 gets a makeover that finally treats Input Tax Credit (ITC) the way finance teams actually work-by separating what belongs to this year from what slipped in from last year, and by giving reclaimed credit a clean, auditable lane. The filing utility is already live on the GST portal and the statutory due date remains 31 December 2025.

Below is a practitioner-friendly deep dive into what changed, why it matters, and exactly how to prepare so you file clean the first time.

What changed at a glance

• Table 6 now segregates ITC
  You'll report prior-year ITC claimed in the current year separately from current-year ITC. Expect two sub-rows popularly referenced as 6A(1) (prior year ITC claimed in FY 2024-25) and 6A(2) (current-year ITC).

• A dedicated lane for reclaimed ITC
  Table 6H is introduced/repurposed to capture ITC reclaimed in FY 2024-25 after earlier reversal, creating an explicit audit trail distinct from fresh claims.

• Table 8 now reads better with IMS and clearer logic
  Table 8A incorporates data flows from the Invoice Management System (IMS); Table 8 computations are tightened, and the new 6A(1) tag helps reduce unexplained 8C/8D variances.

• Tables 12 & 13 are mandatory again
  You must disclose FY 2024-25 ITC claimed/reversed in FY 2025-26 GSTR-3B, ensuring the "post-year" adjustments are on the record.

• Special capture for imports claimed in the next FY
  Trade guidance notes a distinct line to disclose cases where IGST on imports is availed in the next financial year, improving cross-year transparency for Bill-of-Entry-linked credits.

• Applicability & thresholds unchanged in spirit
  Taxpayers with ≤ Rs. 2 crore aggregate turnover are exempt from GSTR-9 for FY 2024-25 onwards; those > Rs. 5 crore must file both GSTR-9 and GSTR-9C (self-certified).

Why the new Table 6 structure matters

For years, one of the biggest friction points in GSTR-9 was inter-year ITC mix-ups: credits pertaining to a prior FY but claimed now would sit alongside current-year credits, confusing Table 8 reconciliation and inviting queries. The split view-6A(1) vs 6A(2)-does three things for you:

1. Prevents false mismatches: Your "brought-forward" claims no longer distort current-year ITC analytics or 2B-vs-Books checks.

2. Shortens the audit trail: Officers (and auditors) can see, at a glance, what is carry-in vs in-year, lowering the need for notices just to ask "which year does this invoice belong to?".

3. Aligns with data plumbing: With IMS feeding 8A and GSTR-1A back-populating outward tables, the form's auto-population behaves closer to real life, so fewer manual overrides.

The reclaimed ITC story: how 6H cleans up the mess

Reversals happen-for vendor non-compliance, payment-linked reversals (Rules 37/37A), or procedural misses. When you later reclaim that ITC, mixing it with fresh credits clouds 8A/8C and your 3B-to-9 trail. Table 6H carves out a clean disclosure lane. That means:

• You don't double count the same invoices in both "fresh ITC" and "reclaimed" buckets. Earlier guidance already emphasized that 6H is exclusive of 6B; the new structure keeps that spirit while improving cross-tables consistency.

• You create an explicit link back to the period of reversal. That excises ambiguity during an officer's review because the reclaim is visibly not "new" ITC.

Tip: Maintain a reclaim memo at invoice level: (i) reason & rule for reversal, (ii) date/period of reversal, (iii) trigger for eligibility restoration, (iv) reclaim period & 3B reference.

Worked examples (use these to test your numbers)

Example 1: Prior-year invoice claimed now (not a reclaim)

• March 2024 invoice missed; ITC of Rs. 1,00,000 claimed in May 2024 3B.

• Report in Table 6A(1) (prior-year ITC claimed in FY 2024-25). Do not put this in 6H-there was no reversal and re-claim sequence.

Example 2: Current-year invoice, reversed and reclaimed within FY 2024-25

• July 2024 invoice claimed, reversed in September (Rule 37A trigger), reclaimed in January 2025 once supplier filed 3B.

• Report the reclaim in 6H for FY 2024-25. Keep your 7-series (reversals) and 12/13 logic tidy to avoid duplication.

Example 3: Import IGST claimed next FY

• March 2025 Bill of Entry; ITC availed in April 2025 (FY 2025-26).

• FY 2024-25 GSTR-9 should use the new import-next-FY line to flag the timing difference so 8A/8C/8D don't go haywire.

How the cross-tables now "talk" to each other

• Table 4/5 (outward) increasingly auto-populate with GSTR-1A adjustments-reducing manual patchwork and aligning returns chronology.

• Table 8A pulls from IMS + regular flows; 8C computation is refined to lessen unexplained gaps. The presence of 6A(1) helps explain legitimate negative/positive swings in 8D without stories.

• Tables 12 & 13 are mandatory-the place where you disclose FY 2024-25 ITC that you actually claimed or reversed in FY 2025-26 3B. Treat these as your official bridge to the next year.

Who must file (and who doesn't)

• Exempt from GSTR-9 for FY 2024-25 onwards: Aggregate turnover up to Rs. 2 crore-vide Notification 15/2025-Central Tax (17-09-2025).

• GSTR-9C requirement:> Rs. 5 crore aggregate turnover must file the reconciliation statement along with GSTR-9 (self-certified under Rule 80).

• Due date: 31 December 2025 (statutory rule) and the portal is live for FY 2024-25 filing.

Your 10-step pre-filing checklist (practical, not preachy)

1. Freeze an "ITC Year Map": Tag every FY 2024-25 ITC line as in-year or prior-year-claimed-this-year. This single column powers 6A(1)/6A(2) accuracy.

2. Build a "Reclaim Register": Invoice-wise ledger with reversal cause, law reference (Rules 37/37A/16(2)), reclaim date, and 3B month-this will feed 6H.

3. Tie to GSTR-2B & IMS: Reconcile Books vs 2B vs IMS status (Accepted/Kept Pending) so you aren't surprised in Table 8.

4. Vendor diligence for Rule 37A: Confirm supplier 3B filing (not just 1) to avoid "eligible-today, reverse-tomorrow" yo-yo.

5. Imports wheel-check: Park any BoE credits availed next FY into the special line; attach BoE copies and ICEGATE proof for quick closure.

6. Month-wise 3B vs Books rollup: Ensure gross ITC, reversals, and net claims tie to your GL movement (inputs/services/capital goods split isn't required, but internal control helps).

7. Outward alignment: With GSTR-1A now back-populating tables, verify that every 1A change has a books narrative (CN/DN/price changes).

8. 12 & 13 tracker: Create a "post-year" sheet for credits of 2024-25 that you touched in 2025-26-you will need it when you file.

9. DRC-03 readiness: If annual true-up shows excess ITC or under-paid tax, compute interest and prepare DRC-03 before final submission.

10. 9C sync (if > Rs. 5 cr): Keep your 9C reconciliation narrative consistent with how you split 6A(1)/6A(2) and 6H; it will make the auditor's life (and yours) easier.

Five common mistakes the new format helps you avoid

1. Dumping carry-in ITC into current-year buckets → Now routed to 6A(1), avoiding 8D noise.

2. Treating reclaims as fresh ITC → 6H isolates reclaims; your 6B stays "pure".

3. Forgetting the next-FY import claims → The distinct import-next-FY line stops silent mismatches.

4. Ignoring mandatory 12/13 → Leads to year-bridge gaps and preventable scrutiny.

5. Assuming 1A edits don't matter → They auto-flow to 4/5; document them.

Documentation you should keep on file

• ITC Year Map (with 6A(1)/6A(2) tags)

• Reclaim Register (with reversal rule, period, reclaim month, proofs)

• Vendor compliance proofs (GSTR-1 and 3B status for Rule 37A scenarios)

• Imports pack (BoE, duty payment proof, credit-avail month, any next-FY tagging)

• IMS screenshots / 2B extracts for disputed invoices (especially those you "Kept Pending" or acted upon).

Frequently asked "but what if…" (quick takes)

• "My supplier uploaded in 1, but didn't file 3B that month."
  Consider Rule 37A risk: if later disallowed, reverse and reclaim via 6H when the condition is cured (supplier's 3B filed). Keep email trails and payment proofs.

• "We missed a few FY 2024-25 invoices and took ITC in April 2025." That belongs to Tables 12/13 (post-year claim) and, if import IGST, also in the import-next-FY line for FY 2024-25 visibility.

• "Do I still need 9C?"
  Yes, if turnover exceeds Rs. 5 crore-it's a self-certified reconciliation that must accompany GSTR-9.

• "I'm under Rs. 2 crore turnover."
  You're exempt from GSTR-9 for FY 2024-25 onwards (you may file voluntarily).

Action plan for November–December

1. Lock your master reconciliations by vendor and month (Books ↔ 3B ↔ 2B/IMS).

2. Populate 6A(1), 6A(2), and 6H from your ITC Year Map + Reclaim Register-then test the impact in Table 8.

3. Prepare Tables 12 & 13 using your April–November 2025 3B activity on 2024-25 invoices.

4. Draft 9C narratives early (if applicable) so nothing contradicts your 9 disclosures.

5. File before the rush (utility is live; plan for approvals/DRC-03, if any).

The bottom line

The split-and-signpost approach to ITC in Table 6 is a welcome, structural fix. It acknowledges that legitimate credits sometimes arrive late, or are reversed and then reclaimed, and it gives both taxpayers and the department a clear, comparable view across years. Combine that with IMS-aware Table 8 logic and mandatory 12/13 bridges, and you have a GSTR-9 that is-finally-aligned to how data moves in the real world. Expect fewer clarification notices, smoother 9C reconciliations, and cleaner year-to-year continuity-provided you do the tagging and registers now.

Disclaimer: The information given in this article is solely for purpose of understanding the law. It is completely based on the interpretation of the author and cannot be constituted as a legal advise, the author of this article and Lawcrux team is not responsible for any legal issues if arises on the basis of the interpretation given above.