The law
CGST Act 2017, Sec 44 and Rule 80
Annual return in GSTR-9 by 31 December following the financial yearSource
Notification 15/2025-CT (17 September 2025), first proviso to Sec 44(1)
Registered persons with aggregate turnover up to ₹2 crore are exempt from GSTR-9 from FY 2024-25Source
CGST Act 2017, Sec 47(2) with Notification 07/2023-CT
Late fee: up to ₹5 crore ₹50 a day capped at 0.04 percent of State turnover; ₹5 to ₹20 crore ₹100 a day capped at 0.04 percent; above ₹20 crore ₹200 a day capped at 0.5 percentSource
GSTR-9 form amended for FY 2024-25 onwards (effective 22 September 2025)
New Table 6A1 (prior year ITC claimed this year), Table 8A based on GSTR-2B, Table 8H1 (import IGST claimed next year); GSTR-1A feeds Tables 4 and 5Source
CGST Act 2017, Sec 44(2), Notification 28/2023-CT
Annual return cannot be filed after three years from its due date; FY 2020-21 barred from 1 December 2025Source
CGST Act 2017, Sec 16(4)
ITC of a year can be taken only till 30 November after the year or the date of filing the annual return, whichever is earlier, so filing GSTR-9 early can cut off pending ITCSource
Government fee
No government fee for filing GSTR-9. Any tax short paid found during preparation is paid with interest through DRC-03. Source: https://taxgarden.in/blog/gst-late-fee-interest-penalty-gstr-3b-gstr-1-gstr-9-guide
Late fee or penalty
Sec 47(2) as relaxed by Notification 07/2023-CT (from FY 2022-23): turnover up to ₹5 crore: ₹50 a day (₹25 CGST plus ₹25 SGST), maximum 0.04 percent of turnover in the State; ₹5 crore to ₹20 crore: ₹100 a day, maximum 0.04 percent; above ₹20 crore: ₹200 a day, maximum 0.5 percent. System calculates it on filing. Source: https://taxgarden.in/blog/gst-late-fee-interest-penalty-gstr-3b-gstr-1-gstr-9-guide