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As the financial year 2024-25 approaches its conclusion, businesses must address key GST compliances to ensure smooth operations in FY 2025-26. Entities involved in zero-rated supplies like exports must submit a Letter of Undertaking (LUT) in Form RFD-11 by 31st March 2025. Eligible businesses can opt for the Composition Scheme by filing Form GST CMP-02 before the same deadline. A new invoice series must commence on 1st April 2025 for systematic record-keeping. Businesses with a turnover exceeding ₹5 crore must assess their e-invoice applicability. Credit notes for returns or refunds must be issued by 30th November 2025, and entities requiring Input Service Distributor (ISD) registration must comply with revised definitions effective 1st April 2025. The GST Amnesty Scheme 2025 offers waivers on interest and penalties for past dues (FYs 2017-18 to 2019-20), requiring dues payment by 31st March 2025 and form submissions by 30th June 2025. Businesses must reconcile GSTR-1, GSTR-3B, ITC registers, and income tax returns, ensuring accurate reporting of taxable income and reversing common credits where necessary. Exporters should verify compliance with Rule 96A, requiring timely exports and receipt of payments in convertible foreign exchange or Indian rupees as permitted. A review of these requirements is critical to avoid defaults and ensure adherence to GST regulations.

1. Submission of Letter of Undertaking (LUT):

Entities involved in zero-rated supplies, such as exports or supplies to Special Economic Zones (SEZs), without paying Integrated GST (IGST), must submit a Letter of Undertaking (LUT) in Form RFD -11 for the upcoming FY by March 31, 2025.

2. Opting for the Composition Scheme:

Eligible businesses to avail the Composition Scheme for FY 2025-26 shall electronically file an intimation in FORM GST CMP-02, duly signed or verified through electronic verification code, on the common portal, either directly or through a Facilitation Centre notified by the Commissioner, prior to the commencement of the financial year for which the option to pay tax under the aforesaid section is exercised i.e.  before 31st march 2025 and shall furnish the statement in FORM GST ITC-03 in accordance with the provisions of sub-rule (4) of Rule 44 of the CGST Rules within a period of sixty days from the commencement of the relevant financial year i.e. by 30th May 2025.9 GST Compliances to Complete Before 31st March 2025

3. Implementation of New Invoice Series:

Businesses are advised to initiate a fresh invoice series starting April 01, 2025. This applies to all transactional documents, including tax invoices, credit notes, debit notes, and bills of supply (exempted supplies), ensuring systematic record-keeping for the new financial year.

4. Check Applicability of E-Invoice:

Any entity is liable to generate an E-invoice in the new financial year based on its turnover crossing the prescribed threshold limit of INR 5 Crore in any of the FYs starting from July 2017.

5. Issuance of Credit Notes:

To comply with GST regulations, ensure that any credit notes for returns or refunds are issued before November 30, 2025.

6. Check the requirement to register as an Input Service Distributor (ISD):

Any office of the supplier of goods or services or both which receives tax invoices towards the receipt of input services, including invoices in respect of services liable to tax under reverse charge, for or on behalf of distinct persons referred to in Section 25 of the CGST Act, shall be required to be registered as Input Service Distributor and shall distribute the input tax credit in respect of such invoices.  The Finance Act, 2024, has substituted the definition of ISD under Sections 2(6) and 20 of the CGST Act to include the distribution of common ITC. As this section is effective from April 01, 2025 vide Notification No. 16/2024-Central Tax, dated August 06, 2024, a taxpayer must identify such entities and apply for ISD registration.

7. GST Amnesty Scheme 2025:

The government has introduced an amnesty scheme to encourage businesses to clear outstanding GST dues under Section 73 of the CGST Act. This scheme offers a waiver of interest and penalties for past FYs of 2017-18, 2018-19, and 2019-20 as per Section 128A of the CGST Act. The deadline for payment of outstanding GST dues is March 31, 2025, and the relevant form submission due date is June 30, 2025.

8. Reconciliation of Various things:

Assesse should do reconciliation of various things.

a. Reconciliation of GSTR 1, 3B and sales to be reported in Income Tax return along with turnover of 26AS. Assesse should make sure that assesse has charged GST on other income which is taxable. Also if said income is not taxable than assesse should reverse comman credit as per rule

b. Reconciliation of ITC register along with GSTR 2B. Also assesse should check for all credit which is reversable if payment is not done in 180 days. Reconciliation of electronic credit register along with books is also recommended.

9. Compliance with Rule 96A of CGST Rules, 2017:

In the case of exporting goods or services under bond or Letter of Undertaking, a taxpayer must comply with the conditions below; otherwise, such supply will be treated as domestic supply.

  • For the export of goods, the export shall be done within 3 months from the date of issue of the invoice for export.
  • For export of services, payment of such services shall be received by the exporter in convertible foreign exchange or in Indian rupees, wherever permitted by the Reserve Bank of India within one year from the date of issue of the invoice for export.

It is recommended that such conditions be reviewed on each invoice regularly; however, as the FY is ending, taxpayers should revisit and ensure there are no defaults.

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Author Bio

CA Ishwar Yadav is GST enthusiast practicing CA. He has vast experience in GST litigation and audit u/s 65 of CGST act. He is speaker on various platforms of ICAI and other. His vision is to helping as many as business owners to reduce compliance burden. He is helping lot of Manufacturing Indust View Full Profile

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Input Service Distributor (ISD) Provisions simplified GST Amnesty Scheme 2024: Key Provisions and Issues GST Amnesty Scheme: Key Provisions and Deadlines View More Published Posts

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