GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2024-25 are now available on the GST Portal.
Taxpayers can now file their annual returns and reconciliation statements in line with the updated formats and instructions, which reflect the recent amendments in GST rules and legislation.
The deadline to file both forms, unless an extension is announced, is 31st December 2025.
🆕 GSTR-9 & 9C: Key Modifications for FY 2024-25
The revised forms include multiple updates based on recent amendments and notifications. Let’s go through them step by step:
1️⃣ Enhanced ITC Reporting and Reversal Requirements
Taxpayers are now required to submit more detailed information regarding Input Tax Credit (ITC).
Reversals must be reported separately as per Rules 37, 37A, 38, 42, and 43.
This is intended to enhance reconciliation accuracy and ensure proper tracking of ITC. 👉 Tip: Before submitting, thoroughly check reversal entries, reclaimed credits, and auto-filled data.
2️⃣ New Fields for Import and Transitional Credit Reporting
New fields have been introduced for reporting import-related ITC and transitional credits.
This promotes greater transparency for businesses importing goods or transferring credits from previous tax regimes. 👉 Tip: Match your import details with the ICEGATE system and verify accuracy before submission.
3️⃣ Auto-Population of Data and Mismatch Handling
The updated forms automatically fetch data from GSTR-1, GSTR-3B, and GSTR-2B.
Several fields will be prefilled to minimize manual mistakes. However, taxpayers should carefully verify and reconcile all details, as discrepancies may trigger future audits.
👉 Tip: Ensure sales, ITC, and outward supply figures are fully reconciled before filing.
4️⃣Late Fee and Interest Reporting Standardized
The revised guidelines mandate clear disclosure of any late fees or interest due under Section 47(2).
All filing delays must be reported transparently in the prescribed form.
👉 Tip: Do not use back-dated entries — ensure the actual delay period and corresponding charges are reported accurately.
5️⃣New Instructions with Relevant Rule References
The instructions for both GSTR-9 and GSTR-9C have been revised to enhance clarity and ease of understanding.
Table references and compliance logic have been simplified to minimize errors in interpretation
👉 Tip: Review the updated instruction sheet before beginning the filing process.
Amidst multiple misleading social media posts regarding significant changes to the GST return system from 1st October 2025, the Goods and Services Tax Network (GSTN) has released a key clarification. This advisory seeks to clear up confusion about the Invoice Management System (IMS) and its effects on GSTR-2B, GSTR-3B, and the auto-population of Input Tax Credit (ITC)
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No Modifications to ITC Auto-Population
GSTN has clearly stated that there is no change in the auto-population of Input Tax Credit (ITC) in GST returns.
The process of auto-populating ITC from GSTR-2B to GSTR-3B will function as it always has. ITC will continue to be auto-filled based on the invoices uploaded by suppliers in their GSTR-1 filings. The introduction of the Invoice Management System (IMS) does not impact this auto-population process.
👉 In summary: Taxpayers are not required to manually import ITC data — the system will continue fetching it automatically.
GSTR-2B Continues to be Auto-Generated Without Manual Input
GSTN has clarified that GSTR-2B will continue to be auto-generated on the 14th of every month, as is currently the case.
There is no need for taxpayers to manually create or trigger GSTR-2B through the Invoice Management System (IMS). GSTR-2B will remain an auto-drafted statement, reflecting both eligible and ineligible Input Tax Credit (ITC) based on supplier GSTR-1 filings.
That said, the new IMS will provide taxpayers with enhanced flexibility to manage their invoice data.
🧾 Key actions available in IMS:
Accept invoices or mark them as pending
Act on credit notes
View the reconciliation summary
Even after GSTR-2B is generated, taxpayers can continue to take these actions in IMS until GSTR-3B is filed. If any updates are made — such as accepting or rejecting invoices or credit notes — GSTR-2B can be regenerated accordingly before submission.
👉 Bottom line: The ITC mechanism remains unchanged, but IMS offers greater control and transparency in handling return data.
New Options for Credit Note Handling Effective October 2025
A major enhancement in Credit Note management will take effect with the introduction of the IMS from the October 2025 tax period.
🧾 Key Highlights:
Greater Control for Recipients: Recipients will now have the option to keep a credit note or related document in a pending state, rather than being required to act on it immediately.
Flexible ITC Reversal: Upon accepting a credit note, recipients can choose to reverse Input Tax Credit (ITC) only to the extent that it was actually availed. This allows for manual adjustment, giving taxpayers more control and precision in calculating ITC.
Purpose of the Change: This flexibility ensures that recipients don’t have to reverse the entire ITC if only a partial credit was claimed initially. It helps avoid unnecessary credit loss and better reflects real-world business transactions.
💡 Implications for Taxpayers
✅ No additional effort needed — ITC auto-population and GSTR-2B generation continue unchanged. ✅ Increased flexibility — taxpayers can manage invoices and credit notes in IMS even after GSTR-2B is generated. ✅ Precise credit reversal — recipients can partially reverse ITC based on the actual amount availed. ✅ IMS enhances transparency without adding complexity to the filing process.
Practical Example
Scenario: You claimed an Input Tax Credit (ITC) of ₹8,000 on an invoice, but later the supplier issued a credit note for ₹2,000. Previously, there was uncertainty about whether you needed to reverse the entire amount.
Starting October 2025 under IMS:
You can accept the credit note, and
Reverse ITC only proportional to the ₹8,000 actually availed — not the full invoice amount.
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📢 Essential Insights
The ITC auto-population process remains unchanged.
GSTR-2B will continue to be auto-generated on the 14th of each month.
IMS introduces flexibility to review, adjust, and regenerate ITC details before filing GSTR-3B.
Credit Note management is enhanced — enabling proportionate ITC reversal and the option to keep notes pending.
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🧮 In Conclusion
The GSTN’s latest advisory reassures taxpayers that the core GST return filing process remains the same, despite IMS integration.
IMS is designed to make the process smarter, not harder — by allowing flexibility and transparency in invoice and ITC management.
Taxpayers are advised to continue filing their returns as usual and use the IMS dashboard for better control and reconciliation.
In summary:
“IMS is not a replacement for GST returns — it’s a smarter way to manage them.”
In the 56th GST Council Meeting (3 Sept 2025), it was decided that refund processing should be risk-based and system-driven, to speed up genuine cases and flag risky ones.
From now, 90% of refund can be sanctioned provisionally if the case is low-risk as per system evaluation.
New Rule 91(2) — Provisional Refund based on Risk Score
The GST system will automatically classify refund applications as “Low Risk” or “High Risk.”
For Low-Risk cases:
90% of the claimed refund will be released provisionally by the officer.
No detailed scrutiny required before provisional sanction.
For High-Risk cases:
Refund will not be sanctioned provisionally.
The officer will carry out detailed verification as per Rule 92.
Officer’s Discretion — When Refund Can Be Withheld
Even if a refund is marked low-risk, the proper officer may decide not to issue provisional refund in specific cases, but he must:
Record written reasons, and
Proceed for detailed scrutiny under Rule 92.
Examples:
Past refund issues pending in appeal,
Previous SCN issued,
Cases under prosecution or fraud detection, etc.
Non-Eligible Persons under Section 54(6)
As per Notification 14/2025-CT (17 Sept 2025), certain categories of taxpayers cannot get provisional refund for zero-rated supplies (exporters).
Also, those under prosecution in last 5 years for evasion > ₹2.5 crore are not eligible for provisional refund.
Systemic Restrictions
Once provisional refund is sanctioned, it cannot be adjusted or withheld for any demand or recovery under Section 54(10)/(11).
If a case has any pending demand or SCN, officer should process refund on final basis instead of provisional.
Provisional refund must be avoided where earlier refund matter is sub-judice or under dispute.
Trade Facilitation — Use of Discretion Sparingly
The new system is meant to facilitate trade, not to delay refunds.
Therefore, the proviso to Rule 91(2) (officer’s power to deny provisional refund) must be used rarely and only with strong justification, not just for routine scrutiny.
Excess Provisional Refund — Recovery Mechanism
If after final scrutiny it’s found that excess refund was given provisionally,
the officer will issue FORM GST RFD-08 (Show Cause Notice) under Section 54 read with Section 73 / 74 / 74A to recover the excess.
Applicability Date
Risk-based provisional refund applies to all refund applications filed on or after 1 October 2025.
Extension to Inverted Duty Refunds (IDS)
Earlier, 90% provisional refund was only for zero-rated supplies (exports).
Now, GST Council recommended to extend this to Inverted Duty Structure (IDS) refunds too.
Formal amendment to Section 54(6) will take time (via next Finance Act + State amendments).
So, as interim trade facilitation, the Centre allowed 90% provisional refund for IDS cases filed on or after 1 Oct 2025—same process as exports.
Processing Flow (Para 3.1 to 3.4)
Step-wise:
Refund application filed (RFD-01).
Officer issues Acknowledgment RFD-02 or Deficiency Memo RFD-03 within prescribed timeline.
Several important changes to the GST return ecosystem have been introduced recently and brought live on the GST portal. Together they tighten compliance, increase reliance on system-generated data and the Invoice Management System (IMS), and reduce the scope for late/retroactive corrections. Below is a practical explainer of each change, its implications, and an easy checklist of actions.
1) Pending GST returns older than 3 years will be blocked on the portal
GSTN has implemented the statutory three-year bar which prevents filing of GST returns beyond three years from their original due date. This enforcement is being rolled out by tax period and taxpayers are being advised that returns older than three years will become non-fileable on the portal once the validation is active for that tax period. In short: if a return’s due date is more than three years in the past, you will not be able to file it on GSTN once the bar is applied for that tax period.
2) Check your GST portal notices:
Tax authorities are active on older years. In particular, the last date for issuing notices under Section 73 (for certain past years) and Section 74 (for other years involving fraud/intentional evasion) is approaching/has been highlighted for specific years — meaning taxpayers should check portal notices immediately and respond where required. If you have not checked notices for FY 2021-22 (Section 73) or FY 2019-20 (Section 74), you may already have pending show-cause action that requires attention.
GSTN has further locked down the relationship between outward supplies reported in GSTR-1 and the summary liabilities reported in GSTR-3B. Values auto-populated from supplier filings will populate GSTR-3B and, for many tables, the taxpayer will not be able to edit those auto-populated figures directly in 3B. Corrections will have to be made via the supplier’s subsequent amendments (or through the prescribed amendment flow), not by free edits in the return. This step is intended to reduce manipulations and mismatches
Practical impact: Buyers must ensure their suppliers file GSTR-1 accurately and on time because once the data feeds into 3B it will be locked. Any mismatch will take longer to correct and could delay or deny ITC until corrected by the supplier.
4) GSTR-2B / IMS: GSTR-2B is now a taxpayer-generated statement via IMS — IMS is central to claiming ITC
The traditional notion of an “auto-generated” GSTR-2B statement is changing: taxpayers will rely more on the Invoice Management System (IMS) to generate and manage the ITC-relevant draft, perform matching, accept/reject invoices, and recompute the ITC position. The IMS now provides a controlled workflow — taxpayers can regenerate GSTR-2B-like reports based on actions taken in IMS rather than passively waiting for a portal report. Because of this, IMS records and actions (accept/reject/mark pending/enter ITC availed) are becoming the authoritative source for ITC claims and reconciliations.
Practical impact: Maintain disciplined IMS practices: reconcile invoices, accept only genuine supplies, and keep IMS comments/evidence. IMS snapshots may become crucial evidence during assessments.
5) Credit notes — recipient reversal of ITC now mandatory in proportion; IMS changes to assist reversal
Where suppliers issue credit notes that reduce taxable value or tax, recipients who have already availed ITC on the original invoice are required to reverse the ITC to the extent it was availed (i.e., reversal only to the extent of ITC actually used; if no ITC was taken, no reversal is needed). IMS has been enhanced to allow recipients to declare the exact ITC availed and reverse only that portion — and suppliers and recipients must coordinate via IMS actions. IMS will reflect amended credit note data and recompute recipients’ ITC accordingly.
Practical impact: Recipients must (a) track ITC availed at invoice level, (b) be ready to reverse only the utilized portion when a credit note is issued, and (c) act promptly on IMS notifications to avoid wrong ITC balances.
6) GSTR-7 (TDS Return) now requires invoice-wise reporting
Form GSTR-7 (the return for tax deductors under TDS provisions of GST) has been updated to require invoice-levelreporting rather than summarized figures. The GSTN portal has enabled invoice-wise filing functionality for GSTR-7 and deductors should prepare invoice-level TDS details for the relevant tax periods. This increase in granularity is meant to improve reconciliation between deductors and suppliers.
Practical impact: TDS deductors (platforms, government departments, etc.) must ensure their systems can provide invoice-level TDS details. Manual or summary reporting is no longer adequate.
Other system & procedural changes you should note
Non-editable auto-populated fields in 3B: The move to auto-populate and lock certain tables in GSTR-3B (from supplier GSTR-1 data) increases the importance of first-time accuracy.
IMS recordability: IMS now supports comments, pending flags, and better audit trail — use these features to create a defensible record.
Partial ITC reversal treatment: If only part of ITC was used, reversal is limited to that used portion; if no ITC was taken on that invoice, no reversal required. This is reflected in IMS logic.
What this means for taxpayers — practical scenarios
Scenario A — You are a buyer who claimed full ITC and supplier issues a credit note later:
You must reverse the ITC equal to the amount you actually availed (not necessarily the full ITC on the invoice) via IMS actions so your GSTR-2B/GSTR-3B position is correct.
Scenario B — You are a supplier and you issued corrected invoices/credit notes:
Your liability reduces in your outward returns, but unless the recipient acts on IMS, their ITC position might not get adjusted automatically. Coordinate via IMS and ensure records are synced.
Scenario C — You rely on old, delayed filings to fix mismatches:
With the three-year bar live, you cannot indefinitely rely on belated filings. If certain historical returns become barred, unresolved mismatches may remain and can trigger notices.
Checklist: Immediate steps for businesses & professionals
Reconcile urgently: Reconcile GSTR-1 vs books vs buyer acknowledgements and clear pending mismatches via supplier follow-ups and IMS actions.
Check GST portal notices: Regularly review notices for FY 2019-20 and FY 2021-22 periods, and respond promptly where required.
Use IMS actively: Accept/reject invoices, record ITC availed at invoice level, and keep a log of IMS actions for audit trail.
Prepare for locked 3B fields: Do not rely on being able to edit 3B later — ensure GSTR-1 accuracy and preserve proof of reconciliations.
Plan for credit-note reversals: Track how much ITC you actually used for each invoice; be ready to reverse accordingly.
For TDS deductors (GSTR-7): Ready your systems to capture invoice-level details; review past months’ records to avoid omission.
Now from 1st October 2025 below more changes are going to be applicable:
The Finance Act, 2025 introduced several amendments in the GST law. The Government has notified that certain sections will be brought into effect from 1 October 2025 through Notification No. 16/2025–Central Tax dated 17 September 2025. Along with this, GSTN has rolled out some major changes in the return filing system and compliance framework.
Activation of Finance Act, 2025 Provisions
From 1 October 2025, the following provisions of the Finance Act, 2025 will come into force:
New Provisions of FA 2025
FA Sec. 121 (ii): This section amends Section 2(69) of the CGST Act, which defines “local authority.” The practical effect is to align the definition with the constitutional usage, which helps avoid any overlap or misinterpretation.
FA Sec. 121 (iii): This provision introduces a new definition, Section 2(116A), for “Unique Identification Marking.” This new legal basis is crucial for the upcoming “track & trace” regime for goods.
FA Sec. 122 & 123: These sections completely omit Section 12(4) and Section 13(4), which previously governed the time of supply for vouchers. This means that the supply of vouchers is now subject to the general time-of-supply rules, simplifying compliance and aligning with global GST practices.
FA Sec. 124: This amendment retrospectively changes the wording in Section 17(5)(d) from “plant or machinery” to “plant and machinery.” The purpose of this change is to retroactively nullify the Supreme Court’s order in the Safari Retreat Case, clarifying the scope of what is covered.
FA Sec. 126: Amendments to Section 34 aim to streamline reporting by introducing changes to the provisions for credit and debit notes. These changes are linked to the new GSTR formats.
FA Sec. 127: A new framework is established under Section 38 for the communication of inward supplies, giving legal recognition to auto-drafted statements like GSTR-2B.
FA Sec. 128: Changes to the monthly return filing under Section 39 (GSTR-3B) will enable stronger invoice-matching and error correction processes.
FA Sec. 129 & 130: Amendment in section 107 & 112 for 10% pre deposit amount requirement
FA Sec. 131: After section 122A of the Central Goods and Services Tax Act, the following section shall be inserted, namely:—
“122B. Penalty for failure to comply with track and trace mechanism.—Notwithstanding anything contained in this Act, where any person referred to in clause (b) of sub-section (1) of section 148A acts in contravention of the provisions of the said section, he shall, in addition to any penalty under Chapter XV or the provisions of this Chapter, be liable to pay a penalty equal to an amount of one lakh rupees or ten per cent. of the tax payable on such goods, whichever is higher.”.
FA Sec.132:Insertion of new section 148A. 132. After section 148 of the Central Goods and Services Tax Act, the following section shall be inserted, namely:—
“148A. Track and trace mechanism for certain goods.—(1) The Government may, on the recommendations of the Council, by notification, specify,—
(a) the goods;
(b) persons or class of persons who are in possession or deal with such goods,
to which the provisions of this section shall apply.
(2) The Government may, in respect of the goods referred to in clause (a) of sub-section (1),—
(a) provide a system for enabling affixation of unique identification marking and for electronic storage and access of information contained therein, through such persons, as may be prescribed; and
(b) prescribe the unique identification marking for such goods, including the information to be recorded therein.
(3) The persons referred to in sub-section (1), shall,—
(a) affix on the said goods or packages thereof, a unique identification marking, containing such information and in such manner;
(b) furnish such information and details within such time and maintain such records or documents, in such form and manner;
(c) furnish details of the machinery installed in the place of business of manufacture of such goods, including the identification, capacity, duration of operation and such other details or information, within such time and in such form and manner;
(d) pay such amount in relation to the system referred to in sub-section (2),
as may be prescribed.”.
FA Sec. 133 & 134: These sections clarify the refund framework by restricting refunds on warehoused goods in Special Economic Zones (SEZ) and Free Trade Warehousing Zones (FTWZ). This change is intended to tighten compliance and prevent fraudulent refund claims.
Invoice-wise Reporting in GSTR-7 (TDS Return)
GSTR-7 has been amended to allow invoice-wise reporting.
Starting from the September 2025 return (due on 10 October 2025), deductors must furnish invoice-wise TDS details.
This ensures better transparency and easier reconciliation for suppliers and tax authorities.
Action Point: Deductors must collect invoice-wise details and update their systems accordingly.
Three-Year Time Bar on GST Return Filing
Returns under Sections 37, 39, 44, and 52 of the CGST Act cannot be filed after three years from their due date.
From October 2025 onwards, the GST portal will block filing of such returns.
Example:
GSTR-1 or GSTR-3B of September 2022 will become time-barred in October 2025.
Annual returns (GSTR-9/9C) for FY 2020-21 will also be time-barred.
Action Point: File all pending returns immediately before the three-year limit expires.
Changes in Invoice Management System (IMS)
GSTN has simplified IMS with effect from October 2025 tax period. Key features include:
Records can be kept “pending” for one period in case of amendments or corrections.
Taxpayers can declare partial ITC reversal instead of full reversal.
Option to save remarks for rejected or pending records, visible to both supplier and recipient.
Applicable only for records filed after rollout.
Impact: This will reduce reconciliation disputes and improve clarity in ITC claims.
Other Changes:
Number
Date
Subject
Download
16/2025-Central Tax
17-Sep-2025
Seeks to notify clauses (ii), (iii) of section 121, section 122 to section 124 and section 126 to 134 of Finance Act, 2025 to come into force.
The Goods and Services Tax Network (GSTN) has notified that the invoice-wise reporting functionality in Form GSTR-7 is now live on the GST portal. This update is in line with Notification No. 09/2025 – Central Tax dated 11th February 2025, which amended Form GSTR-7 to enable capture of invoice-wise reporting of Tax Deducted at Source (TDS) under GST.
What is Form GSTR-7?
Form GSTR-7 is a monthly return filed by TDS deductors under GST. It contains details of:
GST deducted at source on payments made to suppliers,
The TDS liability payable and paid, and
Details of TDS deducted available for suppliers to claim in their Electronic Cash Ledger.
Until now, the reporting in GSTR-7 was summary-based, i.e., deductors provided consolidated details of TDS.
What Has Changed?
With the amendment and the new functionality:
Invoice-wise reporting has become mandatory in GSTR-7.
Deductors will now be required to enter invoice-level details on which TDS has been deducted.
This ensures greater accuracy, transparency, and easy reconciliation for suppliers.
Effective Date
The functionality is operational from the September 2025 tax period.
This means while filing Form GSTR-7 for September 2025 onwards, deductors must provide invoice-wise reporting.
The due date for filing GSTR-7 for September 2025 is 10th October 2025.
What Deductors Should Do
Collect and prepare invoice-wise data of all payments on which GST TDS has been deducted.
Ensure proper matching of invoice details with suppliers’ GST invoices.
Upload invoice-wise TDS details while filing GSTR-7 from September 2025 onwards.
Issues & Grievance Redressal
In case of any technical difficulty in filing, deductors can:
Raise a grievance through the Self-Service Portal on the GST portal.
Provide complete details (error screenshots, GSTIN, period, invoice details, etc.) to enable quick resolution by GSTN.
Key Takeaway
From September 2025 return period onwards, invoice-wise reporting is mandatory in GSTR-7. Deductors must gear up their systems and processes to ensure compliance, as this will bring enhanced transparency and benefit both deductors and suppliers by reducing mismatches in TDS reporting.
The Central Board of Indirect Taxes and Customs (CBIC) has issued Circular No. 252/09/2025-GSTto streamline the process of validating communications issued through CBIC’s eOffice platform. This update reduces duplication and simplifies verification for taxpayers, businesses, and stakeholders.
Key Background
Earlier, CBIC mandated quoting of Document Identification Number (DIN) on all communications (Circulars 122/41/2019 & 128/47/2019).
Later, Circular No. 249/06/2025 clarified that where communications on the GST common portal carried a verifiable Reference Number (RFN), a separate DIN was not required.
Until now, communications issued through CBIC’s eOffice system also required a DIN because there was no mechanism to verify the automatically generated “Issue Number.”
What Has Changed?
With the release of this circular, CBIC has announced:
For communications dispatched using public option in eOffice, the automatically generated Issue Numberwill now be deemed as the Document Identification Number (DIN).
A separate DIN need not be generated in such cases.
DIN Still Mandatory in Other Cases
DIN must continue to be quoted where:
Communication is not dispatched via eOffice’s public option.
Communication does not carry an RFN from GST common portal.
Compliance Instructions for CBIC Officers
While drafting documents in eOffice, officers must correctly fill metadata (document type, recipient name, address, and email).
The issuing office name will auto-populate from the system.
Accuracy in metadata is essential, as these details will be used for online verification.
Modifications to Previous Circulars
This circular modifies earlier directions to the extent noted:
Circular No. 122/41/2019-GST (05 Nov 2019)
Circular No. 128/47/2019-GST (23 Dec 2019)
Circular No. 249/06/2025-GST (09 June 2025)
Now, eOffice Issue Numbers are considered valid DINs, removing redundancy.
Practical Example for Businesses
Example 1: Communication via GST Portal
A taxpayer receives an order via GST common portal with RFN.
RFN is sufficient. No DIN is required.
Example 2: Communication via eOffice (Public Option)
A taxpayer gets a notice from CBIC eOffice with Issue Number.
The taxpayer can verify this at CBIC’s new utility. DIN is not separately needed.
Example 3: Email/Letter Not via Portal or eOffice
A taxpayer receives an email/letter without RFN or eOffice Issue Number.
A valid DIN must be quoted on such communication.
Impact on Taxpayers & Businesses
Simplified verification of CBIC communications.
Reduced duplication of DIN and Issue Numbers.
Stronger safeguards against fraudulent or unauthenticated notices.
Conclusion
Circular No. 252/09/2025 is a step towards ease of doing business by eliminating duplicate identification requirements and offering a simple online utility for verification. From now onwards, taxpayers can rely on the eOffice Issue Numberitself as a valid DIN for authenticity of communications.
he Goods and Services Tax Network (GSTN) has rolled out important changes in the Invoice Management System (IMS) to simplify GST compliance and reduce taxpayer burden. These updates will apply from the October 2025 tax period.
Below is a detailed breakdown of the changes, with practical examples for easy understanding:
Pending Action for Specified Records
Taxpayers can now keep certain records in pending status for one tax period only.
Monthly filers: 1 month
Quarterly filers: 1 quarter
Eligible Records
a. Credit Notes or upward amendments of Credit Notes
b. Downward amendment of CN where the original CN was rejected
c. Downward amendment of Invoice/Debit Note where the original Invoice is already accepted and GSTR-3B filed
d. E-Commerce Operator (ECO) document downward amendment where the original is accepted and GSTR-3B filed
Example:
A supplier issues a credit note of ₹50,000 in October 2025, but the recipient is verifying stock details. The recipient can mark this credit note as Pending and take action in the November return (if monthly) or next quarter (if quarterly).
Declaring ITC Reduction Amount
GSTN clarifies that Input Tax Credit (ITC) needs to be reversed only if availed.
If ITC never availed → No reversal.
If ITC partially availed → Reverse only to the extent availed.
New IMS Facility
Taxpayers can now enter the actual ITC availed and specify the exact amount to be reversed—fully or partially.
Example 1:
Invoice value ₹1,00,000 + GST ₹18,000.
Recipient availed ITC of only ₹9,000 earlier.
Supplier later issues a credit note reducing the taxable value. Recipient needs to reverse only ₹9,000, not the full ₹18,000.
Example 2:
If no ITC was claimed on the invoice, no reversal is required even if a credit note is issued.
This prevents unnecessary reversals and over-compliance.
Option to Save Remarks
While rejecting or keeping a record pending, taxpayers can now add remarks (feature rolling out soon).
Remarks will appear in GSTR-2B for the recipient and in the Outward Supplies dashboard for the supplier.
Suppliers can use these remarks to correct invoices promptly.
Example:
“Price mismatch – awaiting revised invoice” can be added as a remark.
The supplier immediately knows the reason for pending/rejection.
Important Dates
Effective from: October 2025 tax period.
Due date for keeping records pending: Based on the tax period when the supplier communicated the document.
Applicability: Only for records filed after the production rollout of these changes.
Compliance Tips
Use the pending option wisely within the allowed month/quarter.
Always declare the actual ITC availed to avoid penalties.
Encourage suppliers to monitor remarks for faster resolution.
Update ERP/accounting systems before the October 2025 filing cycle.
Conclusion
These updates—pending actions, flexible ITC declaration, and remark sharing—make the GST system more transparent and user-friendly. Businesses should familiarize themselves with the process to avoid last-minute filing errors once the changes go live.
The Central Board of Indirect Taxes and Customs (CBIC) has released a comprehensive consolidated document containing the latestGST rates on goods, effective from 22nd September 2025. This step has been taken to provide greater clarity to taxpayers, traders, and businesses by compiling all recent notifications and amendments into a single updated list.
The GST Council, in its recent meeting, announced major changes in GST rates across multiple categories of goods. These changes, effective from 22.09.2025, are aimed at rationalizing tax slabs, reducing consumer burden on essential items, and boosting demand in sectors like FMCG, automobiles, and consumer durables.
How to Access the Official List
The consolidated list has been published on the official CBIC GST portal and can be downloaded in PDF format. Stakeholders are advised to check the latest rates before issuing invoices post 22.09.2025.
The Central Board of Direct Taxes (CBDT) has released a circular (13/2025) wherein certain benefit has been given to those who claimed Section 87A tax rebate for special rate income like short term capital gains (STCG) on sale of equities and got a tax notice with demand.
According to this circular, if you had claimed Section 87A tax rebate on special rate income like STCG on equities and this claimed was accepted also, then you can get a tax demand notice. However, if you pay this tax demand by December 31, 2025 then any penal interest if levied will be waived. If you don’t pay the tax demand by December 31, 2025 for such Section 87A tax rebate cases then the interest will be levied.
Expert said to ET Wealth Online: “This circular provides indication to those taxpayers who could have claimed Section 87A tax rebate on STCG income prior to July 5, 2024. These taxpayers will get a tax notice for claiming Section 87A tax rebate. After judgment of Bombay High Court for restricting 87A claim in ITR and several lower court judgments allowing 87A, relief was expected from income tax department. However, by issuing this circular department, it is clear that litigation on 87A is likely to increase. Circular give marginal relief that even if tax payer doesn’t pay demand within 30 days of receiving this tax notice, interest at 1% per month will not be payable. This present circular (13/2025) has waived off the interest, if the taxpayer pays the tax demand on or before December 31, 2025.”
What did CBDT say in the circular?
CBDT in the circular (13/2025) dated September 19, 2025 said the following:
The provisions of Section 115BAC(1A) of the Income-tax Act, 1961 are subject to the other provisions of Chapter XII. Therefore, incomes chargeable to tax at special rates specified under various provisions of Chapter XII are not included while determining the chargeability to tax under Section 115BAC(1A). Further, the clause (b) of proviso to Section 87A is applicable to incomes chargeable to tax under Section 115BAC(1A).
It is noticed that in certain cases, the returns had already been processed and rebate was allowed under Section 87A on incomes chargeable to tax at special rates. In such cases, rectifications have to be carried out to disallow such Section 87A tax rebate, which has been incorrectly allowed. Such rectifications will result in demands getting raised. If the payments of such demands raised are delayed then the same are liable for charging of interest under Section 220 (2).
In order to mitigate the genuine hardship arising to such taxpayers on account of interest payable under Section 220 (2), the CBDT in exercise of its powers conferred under Section 119, directs that the interest payable under Section 220(2) shall be waived in such cases where the payment of the tax demands raised, is made on or before December 31, 2025.
In such cases, if a taxpayer fails to pay the tax demand raised as a result of rectification order passed by the CPC on or before December 31, 2025, the interest shall be charged under Section 220(2) from the day immediately following the end of the period mentioned in sub-section (1) of Section 220.
Circular 13/2025
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What is the issue that is causing such problems regarding claiming of 87A tax rebate
According to an earlier Economic Times report dated July 21, 2024, the ITR filing utilities stopped allowing tax rebate under section 87A for various special rate incomes including short-term capital gains on equity shares or equity-oriented mutual funds taxable at 15% under Section 111A.
ITR-2 Schema
“Earlier the Income Tax Utility Software allowed filing of ITRs with rebate, but after July 5, 2024, a whole controversy arose due to change of schema of utility software by the income tax department. Pursuant to those ITRs which were filed with tax rebate are now getting intimation notices for tax demand equivalent to amount to rebate availed. Recently, more than 500 demand notices were received by members of Chartered Accountants Association Surat. Where there was a refund due, the amount of rebate was deducted from it after processing of the ITR,” said Expert
Once the rebate facility was stopped, taxpayers could not claim 87A rebate in conjunction with the special tax rate like STCG. Many people were previously allowed to make this claim, and now they are receiving tax demand notices as a result. “Those taxpayers who have claimed rebate, using old utility or adjusting 87A rebate amount, are now getting a tax notice wherein tax demand is raised with reduced amount of rebate,” said Expert