GST Circular No 246/2025
The circular clarifies the applicability of late fees for delays in furnishing FORM GSTR-9C. Before August 1, 2021, taxpayers with an aggregate turnover above ₹2 crore were required to submit an audited reconciliation statement (GSTR-9C) along with their annual return (GSTR-9). After this date, the audit requirement was removed, and only taxpayers with a turnover exceeding ₹5 crore had to submit a self-certified GSTR-9C with their annual return by December 31 following the financial year.
Late fees under Section 47 of the CGST Act apply if both GSTR-9 and GSTR-9C (where applicable) are not submitted by the due date. If only GSTR-9 is filed on time while GSTR-9C is delayed, the annual return is considered incomplete, and the late fee is calculated from the original due date until the complete return is furnished. However, the late fee is not imposed separately for GSTR-9 and GSTR-9C but as a combined
penalty for the delay in submitting the full annual return.
As per Notification No. 08/2025-Central Tax, late fees for delayed filing of annual returns up to FY 2022-23 have been waived if GSTR-9C is submitted by March 31, 2025. No additional late fee will apply beyond the standard late fee under Section 47, provided GSTR-9C is filed within this deadline. However, any late fee already paid will not be refunded. The circular instructs tax authorities to issue trade notices for awareness and report any implementation issues to the Board.
