In a representation dated December 11, addressed to Finance Minister Nirmala Sitharaman, the Central Board of Indirect Taxes and Customs (CBIC), the GST Council Secretariat and senior GST officials in Mumbai, BCAS said recent amendments to the annual return forms have substantially increased compliance complexity.
BCAS stated that frequent changes to GSTR-9 and GSTR-9C through multiple notifications, including those issued in 2024 and 2025, have created a “moving target” for compliance.
According to the body, taxpayers have had to repeatedly modify data systems, reconciliation processes and reporting mechanisms.
The society highlighted that amendments applicable to FY25 reverse several long-standing relaxations, requiring detailed segregation and tracking of data rather than simple consolidation of monthly or quarterly filings. It pointed to increased granularity in input tax credit (ITC) reporting, mandatory rule-wise break-ups of ITC reversals, separate reporting of reclaimed credits, and new disclosure requirements for import-related IGST credits.
BCAS also flagged challenges arising from revised auto-population logic in certain tables, which it said has added new reconciliation issues for taxpayers.
Given the scope of changes and the additional time required for accurate compliance, BCAS urged the authorities to grant an extension for filing GSTR-9 and GSTR-9C to reduce the risk of errors and mismatches.