11-Jul-2025 Important GSTN Advisory : GST Return Filing to Be Barred After 3 Years From the Due Date of Such Return
#gstcompliance #gstreturns #indirecttax #taxdeadline #taxplanningFrom July 2025, GST returns older than 3 years (e.g., June 2022 and earlier) will be barred from filing. Taxpayers should reconcile and file pending returns by 31st July 2025 to avoid penalties. We are ready to assist with this process.
As per the GSTN Advisory issued on June 18, 2025, and in accordance with the Finance Act, 2023 (Act No. 8 of 2023) dated March 31, 2023,implemented w.e.f. 01-10-2023 vide Notification No. 28/2023 – Central Tax dated 31th July, 2023, the taxpayers shall not be allowed to file their GST returns after the expiry of a period of three years from the due date of furnishing said return under following sections:
| Section | Description | Relevant GST Return Forms |
|---|---|---|
| Section 37 | Outward Supply | GSTR-1, GSTR-1A |
| Section 39 | Payment of Liability | GSTR-3B, GSTR-4, GSTR-5, GSTR-5A, GSTR-6, GSTR-7, GSTR-8 |
| Section 44 | Annual Return/Reconciliation Statement | GSTR-9/GSTR-9C |
| Section 52 | Tax Collected at Source (TCS) | GSTR-8 |
Hence, above mentioned returns will be barred for filing after expiry of three years. The said restriction will be implemented on the GST portal from July 2025 Tax period. Which means any return for which due date was three years back or more and hasn’t been filed till July 25 Tax period will be barred from Filling. In this regard an advisory was already issued by GSTN on October 29th, 2024,June 18,2025.
Illustration :
For ease of reference and better clarity, the latest GST returns that will be barred from filing w.e.f. 1st August 2025 are detailed in the table below:
| GST Forms | Barred Period (w.e.f. 1st August 2025) |
|---|---|
| GSTR-1/IFF | June-2022 |
| GSTR-1Q | April-June 2022 |
| GSTR-3B/M | June-2022 |
| GSTR-3BQ | April-June 2022 |
| GSTR-4 | FY 2021-22 |
| GSTR-5 | June-2022 |
| GSTR-6 | June-2022 |
| GSTR-7 | June-2022 |
| GSTR-8 | June-2022 |
| GSTR-9/9C | FY 2020-21 |
APMH Remarks:
It is imperative to recognise that the referenced amendments have been brought into force with effect from 01st October 2023. By implication, these provisions are applicable to returns due for filing from October 2023 onwards. Consequently, the operational restriction on delayed return filing should logically apply from October 2026. However, the recent GSTN advisory states that this restriction will be implemented on the GST portal from the July 2025 tax period—an interpretation that appears misaligned with the statutory framework and is potentially open to legal contest.
While the overarching objective of the amendment is to instill rigour and timeliness in statutory compliance, it is equally critical to account for ongoing litigations and unresolved tax positions. Allowing taxpayers to file belated returns—particularly in such contested scenarios—would not only aid departmental clarity but also facilitate the seamless flow of input tax credit to recipients, especially where credit transmission is dependent on timely supplier compliance through the portal.
Given the high compliance risk and exposure to penalties, it would be prudent for taxpayers to avoid litigation and instead focus on proactive regularisation. We strongly advise a thorough reconciliation of accounts and immediate action to file all pending GST returns, especially those pertaining to periods prior to June 2022, well before the cut-off date of 31st July 2025. This pre-emptive approach will ensure statutory alignment and mitigate the risk of future disputes.
Should you require our strategic support in reviewing, identifying, and filing any outstanding returns, our team is available to assist you promptly and comprehensively.
Please feel free to reach out at info@apmh.in for any clarification or support required in complying with these changes.