Answer

1. F

   Facts

   Notification 08/2025-CT waived late fee beyond the GSTR-9 filing date for years up to FY 2022-23, but only if GSTR-9C was filed by 31 March 2025. That window has closed.

2. P

   Provisions and law

   • Notification 08/2025-CTFor annual returns up to FY 2022-23, late fee beyond the GSTR-9 filing date was waived if GSTR-9C was filed by 31 March 2025.
   • Circular 246/03/2025-GSTLate fee for an incomplete annual return runs from the due date till both GSTR-9 and GSTR-9C (where required) are filed; there is no separate fee for each.
   • Sec 39(11), CGST Act 2017A return cannot be filed after three years from its due date, subject to conditions notified.
3. A

   Analysis

   If you missed that date, the normal late fee applies. Also, from the July 2025 changes, returns cannot be filed after three years from their due date, and GSTN advisories listed FY 2020-21 GSTR-9 and 9C as barred from 1 December 2025. For FY 2019-20 the form may no longer be fileable. Take advice on how to respond if a notice comes.

4. C

   Conclusion

   1. 1Check which years' 9C are pending.
   2. 2See whether the portal still allows filing for each year.
   3. 3File immediately where allowed and pay late fee.
   4. 4Keep reconciliations ready to answer any notice.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.