Advisory issued by Goods & Service Tax Network

• Goods and Services Tax Network (GSTN) has recently issued an advisory wherein the outward tax liability as reported in Table 3.1 of Form GSTR-3B has been made non-editable, effective from the July 2025 tax period.
• The said advisory may have the below implications.

Currently:

• Auto-Population of Form GSTR-3B:

The GST portal currently provides a pre-filled Form GSTR-3B where tax liability is auto-populated based on outward supplies reported in Form GSTR-1/GSTR-1A/Invoice Furnishing Facility (IFF). These values are presently in an editable format in Form GSTR-3B.

• Amendments to be carried out through GSTR-1A:

GST portal currently provides a formality for carrying out any amendment in the outward supplies declared in Form GSTR-1/IFF within the same return period by way of filing of Form GSTR-1A.

Going Forward – From July 2025 Onward:

• Non-Editable GSTR-3B:

Effective July 2025, the auto-populated liability in Form GSTR-3B will become non-editable. Any necessary amendments in the outward supplies declared in Form GSTR-1 are to be carried out by filing of Form GSTR-1A, which may be filed before filing of Form GSTR-3B for the relevant period.

• Further, Form GSTR-1A can be filed only once for a particular tax period even if return in Form GSTR-3B is not filed. For amending the records reported in the previously filed Form GSTR-1 the functionality of amending the same, in the subsequent Form GSTR-1 is expected to continue.
• The said advisory (hard locking of auto-populated liability in Form GSTR-3B) was initially sought to be implemented from January 2025 tax period but is now set to be implemented from July 2025 returns.
• We recommend reviewing your GSTR-1/IFF filings carefully and using the Form GSTR-1A facility for any corrections prior to filing of monthly return in Form GSTR-3B, starting with the July 2025 tax period.

The locking of reporting outward supplies in Form GSTR-3B enhances return authenticity but necessitates timely and accurate reporting in GSTR-1/IFF, with GSTR-1A now being the only corrective window. The taxpayer should establish internal checks to finalize outward supplies before filing Form GSTR-3B, as post-filing rectification will no longer be feasible for the same tax period.

GSTN has also issued an advisory barring filing of GST returns after expiry of three years. Effective July 2025 tax period onward, the GST portal will restrict filing of GST returns beyond three years from their respective due dates. The said advisory is in accordance with the provisions of the Finance Act, 2023 read with Notification No. 28/2023 – Central Tax dated July 31, 2023.

• The GST returns covered in the advisory are provided below:
• GSTR-1 (declaration of outward supplies),
• GSTR-3B (monthly return)/ GSTR- 4 (composition scheme)/ GSTR-5 (non-resident taxable person)/ GSTR-5A (non-resident OIDAR service providers),
• GSTR-6 (Return for Input Service Distributor),
• GSTR-7 (Tax deduction at source)/ GSTR-8 (e-commerce operator required to collect TCS) and
• GSTR-9 (annual return)

This advisory underscore the importance of timely GST compliance, as delayed return filings beyond three years will no longer be permitted. Taxpayers are therefore advised to promptly reconcile their records and ensure that any pending GST returns for earlier periods are filed without further delay. This will help avoid potential non-compliance, as the GST portal will no longer permit filing of returns beyond the three-year limitation period effective from the July 2025 tax period onward.

We hope you have found this information useful. For any queries/clarifications please write to us at insights@elp-in.com or write to our authors:

Stella Joseph, Partner – Email – StellaJoseph@elp-in.com;

Anushree Kothari, Senior Associate – Email – anushreekothari@elp-in.com;

Harsh Mawar, Associate, Email – HarshMawar@elp-in.com