GST Annual Compliance Checklist for Manufacturers: 2024–25 Edition

As the financial year winds down, manufacturing companies face a critical window to complete their GST compliance obligations. This checklist, prepared by our GST practice team, covers every major action point for FY 2024–25.

1. Monthly / Quarterly Return Filing Status

Ensure all periodic returns are filed and there are no outstanding liabilities:

• GSTR-1: All months/quarters filed with accurate HSN-wise summary
• GSTR-3B: All months/quarters filed with tax payment done on time
• No outstanding DRC-03 demands from prior periods
• IFF (Invoice Furnishing Facility) filed where applicable for QRMP taxpayers

2. Input Tax Credit (ITC) Reconciliation

This is the most important compliance step for manufacturers:

• Reconcile GSTR-2B with your purchase register — identify and resolve mismatches
• Ensure ITC is claimed only for invoices appearing in GSTR-2B
• Reverse ITC on blocked credits under Section 17(5): motor vehicles, food, cosmetics, personal expenses
• Reverse ITC proportionately for exempt/nil-rated supplies (Rule 42 reversal)
• Reverse ITC for inputs/capital goods used in non-business purposes
• Check that all inter-unit stock transfers have proper GST invoices and ITC is claimed correctly

3. GSTR-9 Annual Return

GSTR-9 must be filed by 31st December 2025 for FY 2024–25 (for taxpayers with aggregate turnover > ₹2 crore):

• Reconcile turnover declared in GSTR-1 vs. books of accounts
• Reconcile ITC as per GSTR-3B with GSTR-2A/2B and books
• Declare any ITC availed beyond GSTR-2B during the year and pay tax + interest
• Include any missed ITC that can still be claimed (deadline: GSTR-9 filing)
• Declare all amendments made in returns of FY 2024–25

4. GSTR-9C Reconciliation Statement

Mandatory for taxpayers with aggregate turnover > ₹5 crore (self-certified from FY 2020–21):

• Reconcile audited financial statement turnover with GSTR-9 turnover
• Explain all differences: advances, export, SEZ supplies, unbilled revenue
• Certify ITC as per GSTR-9 against ITC as per audited accounts
• Declare additional liability, if any, arising from reconciliation

5. Common GST Pitfalls for Manufacturers

a) CAS-4 and GST on Captive Consumption

If your company produces goods that are captively consumed in further production (e.g., semi-finished goods transferred between plants), GST is applicable on such supplies. The taxable value is determined based on the CAS-4 cost of production certificate. Ensure CAS-4 certifications are up to date and GST is being paid correctly.

b) Job Work Taxation

Goods sent for job work and not returned within 1 year (3 years for capital goods) are deemed supply. Reconcile your job work inventory and ensure all time limits are met.

c) Export Refunds

If you're claiming export refunds (IGST refund or ITC refund under Letter of Undertaking), ensure all refund applications are filed and pending refunds followed up with the jurisdictional office.

d) E-Way Bill Compliance

Mismatch between e-way bill data and GST returns is a red flag for GST officers. Reconcile e-way bill portal data with GSTR-1 before filing GSTR-9.

6. Key GST Dates for FY 2024–25 (April–March)

7. Action Plan

1. June–July 2025: Complete ITC reconciliation for all months of FY 2024–25
2. August 2025: Finalise GSTR-9 draft — share with auditors
3. September–October 2025: Complete GSTR-9C reconciliation with audited accounts
4. November 2025: File GSTR-9 & GSTR-9C ahead of the December deadline