GST Advisory: 3 Years GST Return rules new effective date announced

The Goods and Services Tax Network (GSTN) has issued an important advisory dated 9th September 2025, reminding taxpayers about the 3-year time limit for filing GST returns. This advisory is based on amendments made in the Finance Act, 2023 (8 of 2023), effective from 1st October 2023 via Notification No. 28/2023 – Central Tax dated 31st July 2023.

🔎 What Does the Rule Say?

As per the amendment, taxpayers will not be allowed to file GST returns after the expiry of 3 years from the due date of furnishing the return.

This restriction applies to the following key sections of the CGST Act:

• Section 37 – Outward Supplies (GSTR-1, IFF, etc.)
• Section 39 – Payment of liability (GSTR-3B, GSTR-4, GSTR-5, etc.)
• Section 44 – Annual Return (GSTR-9, 9C)
• Section 52 – TCS Returns (GSTR-8)

✅ Returns Covered

This includes most compliance forms:

• GSTR-1, GSTR-1A, IFF
• GSTR-3B (Monthly/Quarterly)
• GSTR-4, GSTR-5, GSTR-5A
• GSTR-6, GSTR-7, GSTR-8
• GSTR-9, GSTR-9C

📅 When Will This Apply?

The restriction will be implemented on the GST portal starting from September 2025 tax period.

👉 This means:

• Any return whose due date is older than 3 years and is still pending will be barred from filing.
• Practically, the system will lock out old returns after the 3-year window.

📊 Illustration: Returns That Will Be Barred from 1st October 2025

⚠️ Example:

• If you missed filing GSTR-3B for August 2022, after 1st October 2025, you will never be able to file it.
• Similarly, if you have not filed GSTR-9 (Annual Return) for FY 2020-21, you will be permanently barred from doing so.

🧾 Why This Matters?

1. Permanent Closure: Once 3 years are over, you lose the right to file the return.
2. Compliance Risk: Non-filing may lead to notices, penalties, late fees, and disallowance of ITC.
3. Reconciliation Issues: Mismatches in GSTR-2A/2B and books of accounts will remain unresolved.
4. Business Impact: Pending returns may affect loan approvals, audits, and vendor relationships.

✅ Advisory to Taxpayers

• Reconcile your records immediately.
• File all pending GST returns before the 3-year cut-off.
• Don’t wait until the portal locks them permanently in October 2025.

🔎 What the Earlier Advisory (7th June 2025) Said

• GSTN reminded taxpayers that, as per Finance Act 2023, no GST return can be filed after 3 years from its due date.
• Covered returns: GSTR-1, 3B, 4, 5, 5A, 6, 7, 8, 9.
• Implementation date: from July 2025 tax period onwards.
• This was a general reminder – “3-year bar rule is coming, reconcile your returns.”
• It referred back to the first advisory issued on 29th October 2024, when this provision was first highlighted.

👉 In short, June advisory = Heads-up alert that the 3-year cut-off will soon start applying (from July 2025 period).

🔎 What the Latest Advisory (9th September 2025) Adds

• It goes one step ahead by giving clear illustration + cut-off periods.
• It specifies exactly which old returns will be barred from 1st October 2025.
• Example: GSTR-3B of Aug 2022, GSTR-1 of Aug 2022, GSTR-9 of FY 2020–21 → all these will be permanently locked after Oct 1, 2025.
• Thus, it’s no longer a general reminder – it is the final warning with dates and examples.

👉 September advisory = Practical effect is now visible – some returns are getting permanently locked after 3 years.

✅ What It Means for Taxpayers

1. Earlier (Oct 2024 & June 2025 advisories) → Awareness stage: Law exists, deadline is coming.
2. Now (Sep 2025 advisory) → Execution stage: Portal will start barring old returns in real-time.

⚠️ Bottom line:

• No more chances after 3 years.
• Any pending returns beyond the 3-year limit will be permanently closed on the GST portal.

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