Import ITC, Reverse Charge, E-Commerce Reporting: GSTR-9 FY 2024-25

While most GSTR-9 discussions focus on regular domestic B2B transactions, three specialized areas create unique reporting challenges: imports of goods and services, reverse charge mechanism (RCM) transactions, and e-commerce operator obligations under Section 9(5). Each has distinct timing considerations, classification rules, and reconciliation requirements.

For FY 2024-25, GSTR-9 introduces Table 8H1, a new provision specifically designed to handle import ITC claimed in the next financial year. Understanding when to use this table versus other ITC tables, how to determine which year RCM transactions belong to, and whether you need to complete Table 4G1 as an e-commerce operator are critical for accurate annual return filing.

This blog post demystifies these special cases, providing clear decision trees and examples for each scenario.

Import of Goods: The Complete Reporting Framework

When you import goods into India, you pay Integrated GST (IGST) at the time of customs clearance through the ICEGATE portal or via customs duty payment. This IGST is eligible as Input Tax Credit, subject to normal ITC conditions.

The Basic Import ITC Flow

Step 1: Import goods, pay IGST at customs
Step 2: Customs clearance completed, Bill of Entry issued
Step 3: Claim ITC on the IGST paid
Step 4: Report in GSTR-3B (Table 4A3 – Import of Goods)
Step 5: Report in GSTR-9 based on timing

Tables for Import of Goods in GSTR-9

Table 6E: ITC on import of goods claimed during FY 2024-25
Table 8G: IGST paid on import of goods pertaining to FY 2024-25 (regardless of when claimed)
Table 8H: ITC on import of goods claimed in FY 2024-25 (from Table 6E)
Table 8H1: ITC on import of goods claimed in FY 2025-26 but pertaining to FY 2024-25 (NEW for FY 2024-25)
Table 8I: Reconciliation difference = 8G – (8H + 8H1)

The Timing Question: When Does Import “Pertain” to a Financial Year?

This is determined by the Bill of Entry date, not when you:

• Placed the order
• Made payment
• Received the goods at your facility
• Claimed the ITC

Bill of Entry date is the legally recognized customs clearance date and determines FY classification.

Scenario 1: Import and Claim in Same FY (Standard)

Facts:

• Bill of Entry date: January 15, 2025 (FY 2024-25)
• IGST paid: ₹5,00,000
• ITC claimed: February 2025 GSTR-3B (FY 2024-25)

GSTR-9 Reporting for FY 2024-25:

• Table 6E: ₹5,00,000 (ITC claimed on imports during FY)
• Table 8G: ₹5,00,000 (IGST paid on imports pertaining to FY)
• Table 8H: ₹5,00,000 (ITC claimed during FY)
• Table 8H1: ₹0 (no next-FY claim)
• Table 8I: ₹5,00,000 – (₹5,00,000 + ₹0) = ₹0 (perfect reconciliation)

Scenario 2: Import in FY 2024-25, Claim in FY 2025-26 (New Table 8H1)

Facts:

• Bill of Entry date: March 25, 2025 (FY 2024-25)
• IGST paid: ₹8,00,000
• ITC claimed: April 2025 GSTR-3B (FY 2025-26)
• Reason for delay: Documentation processing, internal approvals, etc.

GSTR-9 Reporting for FY 2024-25:

• Table 6E: ₹0 (no ITC claimed during this FY)
• Table 8G: ₹8,00,000 (IGST paid on imports pertaining to this FY)
• Table 8H: ₹0 (no ITC claimed during this FY)
• Table 8H1: ₹8,00,000 (ITC claimed in next FY but pertaining to this FY)
• Table 13: ₹8,00,000 (ITC of this FY availed in next FY)
• Table 8I: ₹8,00,000 – (₹0 + ₹8,00,000) = ₹0 (perfect reconciliation)

GSTR-9 Reporting for FY 2025-26 (when that year comes):

• Table 6E: Will include ₹8,00,000 (because claimed in FY 2025-26)
• But recognize it’s not FY 2025-26 import, it’s FY 2024-25 import claimed late

Key Insight: Table 8H1 is the counterpart to Table 8C for imports. Just as Table 8C captures missed domestic ITC claimed in next FY, Table 8H1 captures missed import ITC claimed in next FY.

Scenario 3: Import in FY 2023-24, Claim in FY 2024-25

Facts:

• Bill of Entry date: March 20, 2024 (FY 2023-24)
• IGST paid: ₹3,00,000
• ITC claimed: April 2024 GSTR-3B (FY 2024-25)
• Within permitted time per Section 16(4)

GSTR-9 Reporting for FY 2024-25:

• Table 6A: ₹3,00,000 (all ITC claimed, including preceding FY)
• Table 6A1: ₹3,00,000 (preceding FY ITC claimed in current FY)
• Table 6E: ₹0 (not reported here, 6E is for current FY imports only)
• Tables 8G/8H/8H1: ₹0 (these are for FY 2024-25 imports, this is FY 2023-24 import)

GSTR-9 for FY 2023-24 (already filed):

• Table 8G: ₹3,00,000 (IGST paid on that FY’s imports)
• Table 8H: ₹0 (you didn’t claim in that FY)
• Table 8H1: ₹3,00,000 (claimed in next FY, which is FY 2024-25)
• Table 13: ₹3,00,000 (disclosed as to be claimed next FY)

Important: Import ITC of preceding FY claimed in current FY goes in Table 6A1, not Table 6E. Tables 8G/8H/8H1 are only for reconciling current FY imports.

Why Table 8H1 Was Introduced for FY 2024-25

Prior to FY 2024-25, import reconciliation couldn’t properly account for timing differences. If you paid IGST in March but claimed ITC in April of next FY:

• Table 8G showed the IGST paid
• Table 8H showed zero (not claimed in same FY)
• Created unexplained difference in Table 8I

Table 8H1 solves this by capturing the next-FY claim, allowing Table 8I to reconcile properly: 8G = 8H (current FY claim) + 8H1 (next FY claim).

Practical Example: Multiple Import Transactions

Your Import Activity for FY 2024-25:

1. April 2024 Import: Bill of Entry April 10, 2024, IGST ₹2,00,000, claimed April 2024
2. September 2024 Import: Bill of Entry Sep 15, 2024, IGST ₹5,00,000, claimed October 2024
3. January 2025 Import: Bill of Entry Jan 20, 2025, IGST ₹3,00,000, claimed January 2025
4. March 2025 Import: Bill of Entry Mar 28, 2025, IGST ₹4,00,000, claimed May 2025 (next FY)
5. March 2024 Import (preceding FY): Bill of Entry Mar 25, 2024, IGST ₹1,50,000, claimed April 2024

GSTR-9 Reporting for FY 2024-25:

Table 6A: ₹2,00,000 + ₹5,00,000 + ₹3,00,000 + ₹1,50,000 = ₹11,50,000 (all ITC claimed during FY)

Table 6A1: ₹1,50,000 (preceding FY import claimed in current FY)

Table 6E: ₹2,00,000 + ₹5,00,000 + ₹3,00,000 = ₹10,00,000 (only current FY imports claimed in current FY)

Table 8G: ₹2,00,000 + ₹5,00,000 + ₹3,00,000 + ₹4,00,000 = ₹14,00,000 (all FY 2024-25 imports by Bill of Entry date)

Table 8H: ₹10,00,000 (from Table 6E)

Table 8H1: ₹4,00,000 (March 2025 import claimed in May 2025)

Table 13: ₹4,00,000 (import ITC of this FY to be availed next FY)

Table 8I: ₹14,00,000 – (₹10,00,000 + ₹4,00,000) = ₹0 ✓

Note: The March 2024 import (₹1,50,000) doesn’t appear in Tables 8G/8H/8H1 because it pertains to FY 2023-24. It appears only in Table 6A1.

Import of Services: Similar but Distinct

Import of services from overseas vendors also attracts IGST, but the mechanism differs slightly from goods.

How Service Import ITC Works

Step 1: Receive services from overseas supplier (no GST registration)
Step 2: Self-assess IGST under reverse charge
Step 3: Pay IGST through cash (not ITC)
Step 4: Claim same amount as ITC (net effect often zero, but process required)
Step 5: Report in GSTR-3B Table 4A4 (Import of Services)

Tables for Import of Services in GSTR-9

Table 6F: ITC on import of services claimed during FY 2024-25

Unlike imports of goods, there’s no separate reconciliation section (like Tables 8G/8H/8H1) for import of services. The reporting is simpler, just Table 6F capturing what you claimed.

Example: Import of Services

Facts:

• Software license from US company: USD 10,000
• Converted: ₹8,20,000
• IGST @ 18%: ₹1,47,600
• You pay IGST in cash, then claim as ITC
• Transaction date: October 2024
• Reported in: October 2024 GSTR-3B

GSTR-9 Reporting for FY 2024-25:

• Table 6F: ₹1,47,600

No Tables 8G/8H/8H1 involvement, those are specific to import of goods.

Timing Consideration for Service Imports

If you import services in FY 2024-25 but pay IGST and claim ITC in FY 2025-26:

• Table 6F: ₹0 (not claimed in FY 2024-25)
• Table 13: Report the amount (to be claimed next FY)
• Next year’s Table 6A1: Include this (preceding FY ITC claimed in current FY)

Reverse Charge Mechanism (RCM): Which Year Does It Belong To?

RCM transactions create unique timing challenges because you often realize the RCM obligation later, sometimes in the next financial year.

Common RCM Scenarios

1. Services from advocates/lawyers
2. Goods transport by road (GTA services)
3. Security/manpower services from unregistered suppliers
4. Director’s sitting fees and commission
5. Services from overseas (import of services | covered above)
6. Purchases from unregistered dealers (specific goods under notification)

The Critical RCM Timing Rule (Per CBIC Clarification)

CBIC Press Release dated July 3, 2019 clarifies:

“Tax which was to be paid on reverse charge basis for FY 2017-18 but was paid during FY 2018-19: Since the payment was made during FY 2018-19, the input tax credit would have been availed in FY 2018-19 only. Therefore, such details will not be declared in the annual return for FY 2017-18 and will be declared in the annual return for FY 2018-19.”

Translation: RCM liability and corresponding ITC are reported in the financial year when you actually paid the RCM, not the FY when the transaction occurred or invoice was dated.

Why This Rule Exists

RCM involves:

• Paying GST as if you’re the supplier (liability)
• Immediately claiming same amount as ITC as the recipient

Since both liability and ITC happen when you pay, both belong to the payment year for GST reporting purposes.

Scenario 1: Transaction and Payment in Same FY (Standard)

Facts:

• Received legal services from advocate: August 2024
• Invoice dated: August 20, 2024 (FY 2024-25)
• GST: ₹18,000 (RCM applicable)
• You paid RCM: September 2024 GSTR-3B
• Claimed ITC: September 2024 GSTR-3B

GSTR-9 Reporting for FY 2024-25:

• Table 6C: ₹18,000 (ITC on RCM supplies)
• Table 9: Tax paid will include the ₹18,000 RCM payment

Scenario 2: Transaction in FY 2024-25, RCM Paid in FY 2025-26

Facts:

• Received GTA services: March 2025
• Invoice dated: March 28, 2025 (FY 2024-25)
• GST: ₹25,000 (RCM applicable)
• You paid RCM: April 2025 GSTR-3B (FY 2025-26)
• Claimed ITC: April 2025 GSTR-3B (FY 2025-26)

GSTR-9 Reporting for FY 2024-25:

• Table 6C: ₹0 (RCM not paid in this FY)
• Table 9: No RCM payment for this transaction
• Table 13: ₹0 (don’t report here, it’s not FY 2024-25 transaction for GST purposes)

GSTR-9 Reporting for FY 2025-26:

• Table 6C: ₹25,000 (RCM paid and ITC claimed in this FY)
• Table 9: RCM payment included

Key Point: Even though the invoice is dated March 2025 (FY 2024-25), for GST annual return purposes, it’s a FY 2025-26 transaction because that’s when you paid RCM.

Scenario 3: Transaction in FY 2023-24, RCM Paid in FY 2024-25

Facts:

• Received manpower services from unregistered: February 2024
• Invoice dated: February 15, 2024 (FY 2023-24)
• GST: ₹50,000 (RCM applicable)
• You realized obligation late, paid RCM: May 2024 GSTR-3B (FY 2024-25)
• Claimed ITC: May 2024 GSTR-3B (FY 2024-25)

GSTR-9 Reporting for FY 2024-25:

• Table 6C: ₹50,000 (RCM paid in this FY)
• Table 9: RCM payment included
• Interest: Should have paid interest for late payment (from March 2024 to May 2024)

GSTR-9 for FY 2023-24 (already filed):

• Nothing reported (RCM wasn’t paid in that FY)

Adjustment in Books: If your accounting year is April-March and you booked this expense in FY 2023-24 books, this creates a timing difference to explain in GSTR-9C:

• Books: Expense booked in FY 2023-24
• GST: RCM and ITC reported in FY 2024-25
• Explanation in Table 13 of GSTR-9C for FY 2024-25 required

RCM in Table 8A: The Exclusion

RCM transactions do not appear in Table 8A (which is based on GSTR-2B).

Why: GSTR-2B shows invoices where the supplier paid GST and filed GSTR-1. For RCM, the supplier doesn’t pay GST, you do. Hence, it won’t appear in supplier’s GSTR-1 and won’t flow to your GSTR-2B.

Implication: When reconciling Table 8D (8A vs. 8B), your RCM ITC claimed (included in Table 6C) doesn’t correspond to anything in Table 8A. This is expected and doesn’t create reconciliation issues because:

• Table 8B is auto-populated only from Table 6B (domestic supplies)
• Table 6C (RCM) is separate and doesn’t feed into Table 8B
• Therefore, no RCM amounts affect the Table 8A/8B/8C/8D reconciliation

Multiple RCM Transactions: Complete Example

Your RCM Activity:

1. Legal services, May 2024: Invoice May 10, 2024, GST ₹15,000, paid May 2024
2. GTA services, August 2024: Invoice Aug 20, 2024, GST ₹30,000, paid September 2024
3. Manpower services, February 2024 (FY 2023-24): Invoice Feb 28, 2024, GST ₹20,000, paid April 2024
4. Legal services, March 2025: Invoice Mar 25, 2025, GST ₹12,000, paid May 2025 (FY 2025-26)

GSTR-9 Reporting for FY 2024-25:

Table 6A: ₹15,000 + ₹30,000 + ₹20,000 = ₹65,000 (all ITC claimed during FY)

Table 6A1: ₹0 (RCM of preceding FY paid in current FY doesn’t go here, different treatment)

Table 6C: ₹15,000 + ₹30,000 + ₹20,000 = ₹65,000 (all RCM paid during FY)

Table 9: Tax paid includes ₹65,000 RCM liability

Transaction 4 (March 2025 invoice, May 2025 payment): Nothing in FY 2024-25 GSTR-9. Will appear in FY 2025-26 GSTR-9.

Why GSTR-9 Doesn’t Have Table 6A1 for RCM

You might notice that RCM paid in current FY for preceding FY transactions (like our Transaction 3 above: February 2024 invoice, April 2024 payment) doesn’t appear in Table 6A1.

Reason: Table 6A1 is specifically for ITC as per GSTR-2B/supplier filings. RCM doesn’t involve supplier filings; it’s your self-assessed liability and corresponding ITC. Therefore, the Table 6A1 mechanism doesn’t apply.

Instead, RCM simply goes into Table 6C of the year you paid it, following the CBIC clarification that payment year determines classification.

E-Commerce Operators: Table 4G1 and Section 9(5)

Section 9(5) of the CGST Act requires certain e-commerce operators to pay GST on supplies made through their platform by other suppliers.

Who Must Complete Table 4G1?

Table 4G1 is only for e-commerce operators who are liable to pay tax under Section 9(5).

Section 9(5) applies to:

• E-commerce operators facilitating supplies by unregistered persons or composition dealers
• Specific services notified under this section (passenger transportation, accommodation services, housekeeping services, restaurant services)

Who Should NOT Complete Table 4G1?

• Regular businesses (non-e-commerce operators)
• E-commerce operators facilitating supplies by fully registered dealers (Section 9(5) doesn’t apply)
• Marketplace sellers (you’re selling on someone else’s platform, you’re not the operator)
• E-commerce operators only dealing in goods (Section 9(5) is currently mainly for specified services)

What to Report in Table 4G1

If you’re an e-commerce operator liable under Section 9(5):

Report the outward supplies on which you paid GST on behalf of the actual suppliers (unregistered persons or composition dealers) using your platform.

This is the gross value of supplies and tax paid by you under Section 9(5).

Example: Restaurant Aggregator Platform

Facts:

• You operate a food delivery app
• Partner restaurants include unregistered and composition dealers
• For orders from these restaurants, you’re liable under Section 9(5)
• FY 2024-25 activity:
  • Gross value of supplies by unregistered/composition restaurants: ₹2,00,00,000
  • GST @ 5%: ₹10,00,000 (paid by you as e-commerce operator)

GSTR-9 Reporting:

• Table 4G1: Report ₹2,00,00,000 (taxable value) and ₹10,00,000 (tax)

Note: This is in addition to your regular outward supplies (your commission income, etc.) reported in other parts of Table 4.

E-Commerce Operators: ITC Considerations

As an e-commerce operator paying tax under Section 9(5):

• You pay GST on supplies made through your platform
• But you don’t receive corresponding invoices for these supplies (you’re not the buyer)
• Therefore, no ITC is available on the GST you pay under Section 9(5)

The GST you pay under Section 9(5) is a cost of doing business (typically recovered from the suppliers through commission or fee arrangements).

Table 4G1 vs. Regular Table 4 Entries

Table 4 (regular sections): Your own supplies (commission income, subscription fees, advertising revenue from your e-commerce platform)

Table 4G1: Supplies made through your platform by others on which you’re liable under Section 9(5)

These are distinct and don’t overlap. Total outward supply in your GSTR-9 effectively includes both.

Example: Ride-Hailing Platform

Facts:

• You operate a ride-hailing app
• Some drivers are unregistered
• You’re liable under Section 9(5) for rides by unregistered drivers
• FY 2024-25:
  • Your commission income from all drivers: ₹50,00,000
  • GST on your commission @ 18%: ₹9,00,000 (you pay this)
  • Rides by unregistered drivers (value): ₹3,00,00,000
  • GST on these rides @ 5%: ₹15,00,000 (you pay under Section 9(5))

GSTR-9 Reporting:

• Table 4 (regular sections): ₹50,00,000 taxable value, ₹9,00,000 tax (your commission income)
• Table 4G1: ₹3,00,00,000 taxable value, ₹15,00,000 tax (rides by unregistered drivers)
• Table 9: Tax paid includes both ₹9,00,000 and ₹15,00,000

Special Case: ISD (Input Service Distributor)

If your organization has an ISD that distributes ITC to you:

Reporting ISD Credit

Table 6D: ITC received from Input Service Distributor

This captures credit distributed to you by your ISD during FY 2024-25.

Example: Head Office ISD

Facts:

• Your head office is registered as ISD
• Head office incurs common expenses (rent, IT services, etc.)
• ITC is distributed proportionally to branches
• Your branch receives: ₹8,50,000 distributed ITC in FY 2024-25

GSTR-9 Reporting for Your Branch:

• Table 6D: ₹8,50,000

Note: This ITC won’t appear in your GSTR-2B (it’s not from a supplier to you directly). It comes through ISD mechanism, hence separate table.

Integration: How These Special Cases Fit Together

Let’s see how imports, RCM, and other special cases integrate in a complete GSTR-9:

Comprehensive Example:

Your FY 2024-25 ITC activity includes:

1. Domestic B2B supplies: ₹75,00,000 (Table 6B)
2. Import of goods (claimed in FY): ₹10,00,000 (Table 6E)
3. Import of goods (claimed next FY): ₹3,00,000 (Table 8H1, Table 13)
4. Import of services: ₹2,50,000 (Table 6F)
5. RCM on domestic supplies: ₹5,00,000 (Table 6C)
6. ISD credit: ₹4,00,000 (Table 6D)
7. Preceding FY ITC: ₹6,00,000 (Table 6A1)

Table 6 Summary:

• Table 6A: ₹75,00,000 + ₹10,00,000 + ₹2,50,000 + ₹5,00,000 + ₹4,00,000 + ₹6,00,000 = ₹1,02,50,000
• Table 6A1: ₹6,00,000
• Table 6A2: ₹1,02,50,000 – ₹6,00,000 = ₹96,50,000

Bifurcation (Tables 6B to 6H):

• Table 6B: ₹75,00,000
• Table 6C: ₹5,00,000
• Table 6D: ₹4,00,000
• Table 6E: ₹10,00,000
• Table 6F: ₹2,50,000
• Table 6I: ₹96,50,000 (sum of 6B to 6F)
• Table 6J: ₹96,50,000 – ₹96,50,000 = ₹0 ✓

Import Reconciliation (Tables 8G to 8I):

• Table 8G: ₹13,00,000 (₹10,00,000 claimed + ₹3,00,000 not yet claimed)
• Table 8H: ₹10,00,000 (from Table 6E)
• Table 8H1: ₹3,00,000 (to be claimed next FY)
• Table 8I: ₹13,00,000 – (₹10,00,000 + ₹3,00,000) = ₹0 ✓

Table 13: ₹3,00,000 (import ITC to be claimed next FY)

Common Mistakes with Special Cases

Mistake 1: Reporting Imports in Wrong Tables

Wrong: Reporting preceding FY import (claimed in current FY) in Table 6E
Correct: Table 6E is only for current FY imports; preceding FY imports go in Table 6A1

Mistake 2: Timing RCM by Invoice Date Instead of Payment Date

Wrong: Invoice dated March 2025, RCM paid April 2025 → Reporting in FY 2024-25
Correct: Report in FY 2025-26 (year of payment) per CBIC clarification

Mistake 3: Including RCM in Table 8A Reconciliation

Wrong: Expecting Table 8D to account for RCM ITC
Correct: RCM doesn’t appear in GSTR-2B, hence not in Table 8A; reconciliation is only for Table 6B (domestic B2B)

Mistake 4: Non-Operators Filling Table 4G1

Wrong: Marketplace seller thinking Table 4G1 applies to them
Correct: Table 4G1 is only for e-commerce operators liable under Section 9(5), not for sellers on platforms

Mistake 5: Forgetting Table 8H1 for Late Import Claims

Wrong: Import in March 2025, ITC claimed April 2025 → Not reporting anywhere in FY 2024-25 GSTR-9
Correct: Must report in Table 8H1 and Table 13 to complete reconciliation

Best Practices for Special Cases

1. Maintain Separate Registers

Import Register:

• Bill of Entry date and number
• IGST amount paid
• Date claimed in GSTR-3B
• FY classification
• Table 6E vs. Table 8H1 designation

RCM Register:

• Transaction/invoice date
• RCM payment date in GSTR-3B
• FY classification based on payment
• Interest calculated if late

E-Commerce Section 9(5) Register (if applicable):

• Platform supplies by unregistered/composition suppliers
• Tax paid under Section 9(5)
• Reconciliation with platform reports

2. Quarterly Review of Import Claims

Don’t wait until year-end to identify imports where ITC hasn’t been claimed:

• Monthly: Check Bill of Entry vs. ITC claimed
• Quarterly: Reconcile with customs data
• Before GSTR-9: Finalize which imports go in Table 6E vs. Table 8H1/Table 13

3. RCM Compliance Calendar

Set reminders:

• Monthly: Review transactions for RCM applicability
• Before GSTR-3B deadline: Ensure all RCM identified and paid
• Annual: Reconcile invoice dates vs. payment dates for correct FY classification

4. E-Commerce Operator Clarity

If you’re an e-commerce operator:

• Review Section 9(5) applicability each quarter
• Segregate supplies by registered vs. unregistered sellers
• Maintain documentation of TCS collected (separate from Section 9(5) obligation)
• Table 4G1 preparation: Maintain month-wise breakup throughout the year

5. Document Timing Differences

For GSTR-9C (if applicable):

• Document imports where books show expense in one FY but ITC claimed in another
• Document RCM where invoice FY differs from payment FY
• Prepare Table 13 explanations for these timing differences

Integration with GSTR-9C

If your turnover exceeds the audit threshold:

Import Timing in Books vs. GST

Books: May recognize import expense when goods received
GST: Recognize ITC when claimed in GSTR-3B

Table 12F Impact: If goods received and booked in March 2025 but ITC claimed April 2025:

• Books (FY 2024-25): Expense includes import
• GSTR-9 (FY 2024-25): ITC not in Table 6E (goes to Table 8H1)
• Creates timing difference to explain in Table 13

RCM in Books vs. GST

Books: Usually recognize expense in transaction FY
GST: Recognize when paid (per CBIC clarification)

Example: Legal fees February 2024 (FY 2023-24), RCM paid April 2024 (FY 2024-25)

• Books (FY 2023-24): Expense ₹1,00,000 + GST ₹18,000
• GSTR-9 (FY 2024-25): RCM ₹18,000 in Table 6C
• Table 13 explanation: “RCM of ₹18,000 pertaining to FY 2023-24 paid in FY 2024-25 as per CBIC Press Release dated July 3, 2019”

Conclusion

Imports, RCM, and e-commerce operator obligations represent specialized areas of GSTR-9 that require careful attention to timing rules and specific table designations. The introduction of Table 8H1 for FY 2024-25 significantly improves import ITC reconciliation by accommodating legitimate timing differences between customs clearance and ITC claim.

Key principles to remember:

1. Imports: Bill of Entry date determines FY classification; use Table 8H1 for imports claimed in next FY
2. RCM: Payment date (not invoice date) determines which FY to report in, per CBIC clarification
3. E-Commerce Section 9(5): Only for operators facilitating supplies by unregistered/composition dealers
4. ISD Credit: Separate table (6D) with no GSTR-2B linkage
5. Reconciliation: Each special case has distinct reconciliation logic, don’t try to force-fit into domestic B2B framework

By maintaining separate registers for each category, understanding timing rules, and documenting differences for GSTR-9C purposes, you can confidently handle these special cases without reconciliation errors or compliance gaps.

Next in series: Late fee calculation for GSTR-9 and GSTR-9C under Section 47(2) – understanding the dual filing requirement, how system calculates fees, and examples of split fees between forms based on filing dates.

Reference:

GSTN’s Consolidated FAǪs on GSTR 9/9C for the FY 2024-25 dated 17/12/2025