GST law prescribes the timeline of 30 November 2026 for some of the crucial actions that are to be taken in respect of transactions pertaining to FY 2025-26.
Summary: The GST action points for FY 2025-26 cover key year-end compliance activities relating to credit notes, input tax credit, reconciliations, reversals, amendments and reporting. Credit notes relating to FY 2025-26 are required to be addressed within the specified timeline, with corresponding customer ITC reversals relevant for reduction of the supplier’s tax liability. Eligible ITC pertaining to FY 2025-26 should be availed within the prescribed timeline, while vendor and GSTR-2B reconciliation should identify unmatched credits and unavailed matched credits. Businesses should also undertake ageing analysis for creditors to identify supplies where payment has remained outstanding beyond 180 days and make the required ITC reversal. Errors and omissions in GSTR-3B and reporting or amendment requirements in GSTR-1 should be completed within the specified timelines. Final annual ITC reversal under Rule 42, including additional reversals or re-availment of excess reversals, should be determined, while appropriate documents should be issued for exempt supplies and business divestments. The checklist further covers cost allocation and cross charge, payment of GST under RCM, including specified services received from related parties outside India without consideration, and issuance of self-invoices for RCM supplies received from unregistered suppliers, including import of services. Other areas include inventory write-offs, e-invoice and e-way bill reconciliation, verification of supplier GSTR-3B filing status under Rule 37A, implications on sale or write-off of capital assets, and reversal of ITC relating to supplier credit notes. The action points are intended to ensure that relevant reconciliations, reversals, payments, amendments and documentation are completed within the specified timelines.
GST Action Points for FY 2025-26
| GST action points for FY 2025-26 | |||
| Sr. No. | Activity | Description | Action points |
| 1 | Issuance of credit notes | As per Section 34 of the CGST Act, 2017 a registered person shall be allowed to raise credit note on invoices issued in FY 2025-26 and adjust the excess tax liability paid only if such credit notes are issued before October 2026 and are accordingly reported in GST returns before 30 November 2026 or the date of furnishing annual return for FY 2025-26 whichever is earlier
The issuance of credit note also requires credit reversals by the customer |
The company should issue all the credit notes for invoices pertaining to FY 2025-26 till the month of October 2026 in order to adjust the tax liability against such credit notes (subject to fulfillment of other conditions specified therein)
Post such a timeline, the company would not be permitted to issue credit note with adjustment of tax liability. However, commercial credit notes may still be issued Further, for the tax credit notes issued therein during FY 2025-26, having confirmation from customers on reversal of corresponding ITC would also be required. Else, the possibilities of authorities denying the benefit of tax liability reduction to the supplier cannot be ruled out |
| 2 | Availment of input tax credit in respect of invoices and debit notes pertaining to FY 2025-26 | As per Section 16(4) of the CGST Act, 2017, a registered person shall not be entitled to claim input tax credit in respect of invoices or debit notes for the supplies received during FY 2025-26 after 30 November 2026 or the date of furnishing annual return for FY 2025-26 whichever is earlier | The company should avail all the eligible credits pertaining to supplies received during FY 2025-26 before the specified timeline |
| 3 | Vendor reconciliation (GSTR-2B reconciliation) | Under GST law, an assessee is required to match ITC to be availed for any invoice with the ITC reflecting in form GSTR 2B of the company
As per amendment to Section 16 of the CGST Act, 2017, which is effective from 1st January 2022 vide Notification No 39/2021 – CT dated 21 December 2021, the company would be allowed to take ITC only with respect to matched credits reflected in form GSTR 2B |
For ITC pertaining to FY 2025-26, the company should undertake an analysis of unmatched credit and perform corrective action on the same in GST return to be filed for the month of October 2026
Similarly, if any matched credit has not been availed, the same should be availed within the timeline specified under Section 16(4) of the CGST Act, 2017 |
| 4 | Reversal of ITC on account of non-payment of consideration to suppliers within 180 days | As per Section 16 of the CGST Act, 2017, if a person fails to pay to the supplier against any inward supply of goods or services within 180 days from the date of issue of invoice, then the credit availed against such invoice is required to be reversed | The company should undertake ageing analysis of the creditors in October 2026 to identify creditors where the payments have been pending for more than 180 days
Input tax credit availed in respect of supplies made by such creditors should accordingly be reversed |
| 5 | Rectification of errors/ omissions in form GSTR 3B filed for FY 2025-26 | As per Section 39 of the CGST Act 2017, all errors or omissions in returns for FY 2025-26 are to be rectified latest by 30 November 2026 or the date of furnishing annual return for FY 2025-26 whichever is earlier | It is pertinent to ensure that all the rectifications in GSTR-3B are done before the specified timelines |
| 6 | Reporting/ amendments for transactions reported in form GSTR 1 for FY 2025-26 | As per Section 37 of the CGST Act, 2017, any reporting error while uploading the details in form GSTR 1 for FY 2025-26 are to be corrected on or before 30 November 2026 or the date of furnishing annual return for FY 2025-26 whichever is earlier | It is pertinent to ensure that all the rectifications in form GSTR-1 including amendment of shipping bill details for export invoice is done when filing GSTR-1 for the month of October 2026 |
| 7 | Final computation of reversal of input tax credit and issuance of documents for exempt supplies | Rule 42 of the CGST Rules, 2017 prescribes that taxpayers with taxable and exempt revenues are required to reverse the input tax credits pertaining to exempt supplies, including on common inputs/input services on a provisional basis each month
Subsequently, the final amount of reversal for the entire financial year needs to be computed. Any excess reversals should be availed as credit in GSTR 3B before October 2026 or less reversals should be paid through GSTR 3B/GST DRC-03 |
ITC reversal computation: |
| – If the company undertakes certain exempt sales which require reversal of ITC on a proportionate basis, the company needs to compute the amount of ITC reversal required for FY 2025-26 and compare the same with reversals already made on a monthly basis. Additional reversal, if required needs to be done at the earliest to avoid interest implications | |||
| Issuance of documents: | |||
| – Issuance of documents such as the bill of supply/tax invoice would be required for business divestments and other exempt supplies | |||
| 8 | Cost allocation / Cross charge | If the company has certain central functions executed from the corporate office such as finance, administrative etc. at the entity level, the company needs to cross charge the amount of such internally generated services performed by the HO to other locations | The company needs to cross charge the cost of these functions on the basis of GST registration and charge applicable GST on the same
Further, Company also needs to issue invoice for GST charge on such cost allocations, and the recipient unit would be eligible to avail input tax credit on the basis of such invoices |
| 9 | Payment of tax on services under RCM including services received from related parties outside India without any consideration | The company is required to discharge GST under RCM on certain prescribed services
Further, services provided by a related party located outside India to the company without consideration are also subject to levy of GST under RCM. It is essential that such services are identified and tax under RCM is discharged on such services |
The Company should ensure that the tax is duly paid for transactions liable to RCM and the ITC thereon has duly been availed |
| 10 | Issuance of self-invoice for RCM supplies received from unregistered dealers including import of service | As per Section 31(3)(f) of the CGST Act, 2017 read with Rule 47A of the CGST Rules, 2017, a registered person liable to pay tax under RCM shall issue an invoice for goods and/or services received from unregistered suppliers
The invoice is required to be issued within the period of thirty days from the date of receipt of the said supply of goods and/or services |
The company needs to issue self-invoices for all such services received from unregistered suppliers including import of service for which company has discharged tax under RCM
In case of non-issuance of the invoice, the ITC eligibility may be questioned by the authorities on account of non-compliance with GST provisions |
| 11 | Inventory write-off | As per Section 17(5)(h) of the CGST Act, 2017, ITC would not be available in respect of goods written off in the books of accounts | In case where any raw material has been written off, proportionate ITC is required to be reversed |
| 12 | E-invoice and E-way bill reconciliation | Reconciliation of the e-invoices and e-way bills generated with turnover reported in form GSTR 1 and form GSTR 3B | The Company should undertake reconciliation of e-invoices, and e-way bills generated with the turnover reported in form GSTR 1 and form GSTR 3B
For differences, the companies would need to analyze its reasons and take corrective actions |
| 13 | Verification of the GSTR-3B filing status of the supplier in compliance with Rule 37A of the CGST Rules, 2017 | In terms of Rule 37A of the CGST Rules, 2017, in respect of all the invoices for which the ITC has been availed in FY 2025-26, GSTR-3B filing status of the supplier is to be verified
If GSTR-3B of the supplier is not filed by 30 September 2026, corresponding ITC availed by the recipient is required to be reversed by 30 November 2026 If the ITC is reversed after 30 November 2026, then the reversal would attract interest implications |
It is important to ensure that the GSTR-3B filing status of all the suppliers in respect of which the ITC has been availed in FY 2025-26 is verified and accordingly necessary action is taken within the specified timelines |
| 14 | Implications on sale or write off of asset | In terms of Section 18(6) of the CGST Act, 2017, in case of sale of capital assets (including plant and machinery), registered person is required to pay an amount equivalent to tax on transaction value or the ITC availed on said capital goods reduced by such percentage points as may be prescribed | In case any capital goods have been supplied during the FY 2025-26, it is important to ensure that the provisions of Section 18(6) of the CGST Act, 2017 have duly been complied with |
| 15 | Reversal of ITC on credit notes issued by suppliers | In terms of Section 34 of the CGST Act, 2017, benefit of tax liability reduction to the supplier issuing credit note is allowed only if the corresponding ITC has been reversed by recipient | It is important that in respect of credit notes issued by suppliers as per appearing in form GSTR-2B of FY 2025-26, a reconciliation is carried out by recipient to ensure that the corresponding ITC has duly been reversed wherever required
Also, basis the reconciliation, if it is identified that if any of the credit notes have inadvertently been issued by the supplier, relevant communication with suppliers may duly be done to ensure that the appropriate corrections are made in Form GSTR-1 at their end within the due timelines specified above If any of the credit notes are reflecting in Form GSTR-2B of the relevant period for which the corresponding ITC has not been reversed by recipient, possibilities of authorities requiring reversal of corresponding ITC during the course of litigation proceedings cannot be ruled out |
