GST WEEKLY UPDATE :36/2025-26 (07.12.2025) By CA Vipul Khandhar

0
Spread the love
Reading Time: 8 minutes

-By CA Vipul Khandhar

1. Auto Suspension of GST Registration due to Non-Furnishing of Bank Account Details as per Rule 10A:

As per Rule 10A, taxpayers (except those registered under TCS, TDS, or Suo-moto registrations) must furnish their bank account details within 30 days of grant of registration or before filing details of outward supplies in GSTR-1 or IFF, whichever is earlier.

The following updates have been implemented on the GST Portal with respect to Rule 10A:

  • Automatic Suspension:

If a taxpayer fails to furnish bank account details within 30 days of registration, the system will automatically suspend the registration. The suspension order can be viewed at: Services > User Services > View Notices and Orders.

  • Adding Bank Account Details:

Taxpayers can add bank account details through a non-core amendment by navigating to: Services > Registration > Amendment of Registration (Non-Core Fields).

  • Automatic Dropping of Cancellation Proceedings:

Once bank account details are furnished, cancellation proceedings will be automatically dropped by the system.

  • Manual Option to Drop Proceedings:

If the cancellation proceedings are not dropped automatically on the same day after adding bank details, the taxpayer can manually initiate the process using the “Initiate Drop Proceedings” button available at: Services > User Services > View Notices and Orders > Initiate Drop Proceedings.

Exemptions:
Furnishing bank account details is not mandatory for OIDAR and NRTP taxpayers. However, for OIDAR taxpayers who select “Representative Appointed in India” as ‘Yes’, furnishing bank account details is mandatory.

  1. Advisory on reporting values in Table 3.2 of GSTR-3B:

Table 3.2 of Form GSTR-3B captures the inter-state supplies made to unregistered persons, composition taxpayers, and UIN holders out of the total supplies declared in Table 3.1 & 3.1.1 of GSTR-3B and is auto-populated from corresponding supplies declared in GSTR-1, GSTR-1A, and IFF in the requisite tables.

It is to inform you that from November-2025 tax period onwards, value of supplies auto-populated in Table 3.2 of GSTR-3B from the returns/forms mentioned above, shall be made non-editable. The GSTR-3B shall be filed henceforth with the system generated auto-populated values only in table 3.2.

Further, in case any modification/amendment is required in the auto-populated values of Table 3.2 of GSTR-3B, then the same can be done through GSTR-1A for the same tax period. The values thus reported in GSTR-1A shall change the auto-populated values of table 3.2 in GSTR-3B instantly and the taxpayers can file their GSTR-3B with the updated values. Moreover, the amendment of such supplies can always be reported in Form GSTR-1/IFF filed for subsequent tax periods.

To ensure that GSTR-3B is filed accurately with the correct values with no hassle of frequent amendments, it is advised to report the correct values in GSTR-1, GSTR-1A, or IFF. This will ensure the auto-populated values in Table 3.2 of GSTR-3B are accurate and compliant with GST regulations.

FAQ’s

  • What are the recent changes related to reporting supplies in Table 3.2?

Starting from the November 2025 tax period, the auto-populated values in Table 3.2 of GSTR-3B for inter-state supplies made to unregistered persons, composition taxpayers, and UIN holders will be non-editable, and taxpayers will need to file their GSTR-3B with the system-generated auto-populated values only.

  • How can I rectify values in Table 3.2 of GSTR-3B if incorrect values have been auto-populated after November 2025 period onwards due to incorrect reporting of the same through GSTR-1?

If incorrect values are auto-populated in Table 3.2 after November 2025, then the taxpayers need to correct the values by making amendments through Form GSTR-1A for the same tax period. The values thus reported in GSTR-1A shall change the auto-populated values of table 3.2 in GSTR-3B instantly and the taxpayers can file their GSTR-3B with the updated values. Moreover, the amendment of such supplies can always be reported in Form GSTR-1/IFF filed for subsequent tax periods.

  • What should I do to ensure accurate reporting in Table 3.2 of GSTR-3B?

Taxpayers should ensure that their supplies are reported correctly in their GSTR-1, GSTR-1A, or IFF. It is advised to review the draft GSTR-1 or GSTR-1A before filing so that any mistakes in the statement can be corrected therein. This will ensure that the accurate values are auto-populated in Table 3.2 of GSTR-3B.

  • Till what time/date I can amend values furnished in GSTR-1 through Form GSTR-1A?

As there is no cut-off date for filing Form GSTR-1A before GSTR-3B which means Form GSTR-1A can be filed after filing Form GSTR-1 and till the time of filing Form GSTR-3B. Hence, any amendment required in auto-populated values of table 3.2, same can be carried out through Form GSTR-1A till the moment of filing GSTR-3B. For more details on filing of GSTR-1A. please click https://services.gst. gov. in/services/advisoryandreleases/read/506

  1. Advisory for FORM GSTR-1A:

The Government vide notification No. 12/2024 – Central Tax dated 10.07.2024, has introduced FORM GSTR-1A which is an optional Form/ facility. This has been provided to the taxpayers to add or amend particulars of a supply of the current tax period, which was missed out or was wrongly reported in FORM GSTR-1 of the said tax period, before filing of the GSTR-3B return of the said tax period.

FORM GSTR-1A would be available to all the taxpayer from August 2024, through which details furnished in FORM GSTR-01 for the month of July 24 can be amended. The salient features of FORM GSTR-1A are –

FORM GSTR-1A is an optional facility. This can be filed only once for a particular tax period.

The corresponding effect of the changes made through FORM GSTR-1A on the liability of the taxpayer shall be reflected in FORM GSTR-3B for the same tax period.

At the recipient end, the ITC for the supplies declared or amended by the suppliers through FORM GSTR-1A will be available to the recipient in FORM GSTR-2B generated for the next tax period.

For the taxpayers filing FORM GSTR-1 on monthly basis:

FORM GSTR-1A will be available on the portal every month from the due date of filing of FORM GSTR-1 or the actual date of filing of FORM GSTR-1, whichever is later, and will be available till the actual filing of corresponding FORM GSTR-3B of the same tax period. It is pertinent to re-iterate that the taxpayer can’t file FORM GSTR-1 for a month until he files FORM GSTR-3B for the previous month.

From the liability perspective, the net impact of particulars declared or amended through FORM GSTR-1A, along with the particulars declared in FORM GSTR-1, shall be auto-populated in FORM GSTR-3B for the same tax period as that of FORM GSTR-1.

 For the QRMP taxpayers, who files FORM GSTR-1 on Quarterly basis:

FORM GSTR-1A shall be available quarterly after actual filing of FORM GSTR-1 (Quarterly) or the due date of filing of FORM GSTR -1 (Quarterly), whichever is later, and will be available till the actual filing of FORM GSTR-3B of the same tax period.

The supplies reported in the FORM GSTR-1 of the current tax period (including those declared in IFF, for the first month, M1 and second months, M2 of a quarter, if any) can be amended through corresponding Quarterly GSTR-1A.

From the liability perspective, the net impact of the particulars declared in GSTR 1A (Quarterly), along with particulars furnished in FORM GSTR-1 (Quarterly) (or through IFF of Month M1 and M2, if filed), shall be auto-populated in FORM GSTR-3B (Quarterly) of the same tax period.

It is reiterated that there will be no separate amendment facility available for records furnished through IFF for the months M1 and M2, during the month M1 and M2.

In case where change is required to be made in GSTIN of a recipient for a supply reported in FORM GSTR-1 of a tax period, the same can be rectified through FORM GSTR-1 for the subsequent tax period only.

  1. FAQs on GSTR -9/9C for FY 2024-25:

        Additional list of Frequently Asked Question along with the response has been compiled in response to comment received from various channel. The additional FAQ dt 4-12-2025 is intended to further assist the Taxpayer in better understanding of various Tables of GSTR-9/9C and their key aspects – such as reporting of various values in Tables. FAQ as under:

Sr. No. Query GSTN Reply
1 If I paid GST on RCM for FY 24-25 in GSTR3B of FY25-26.

Should this liability and ITC of RCM be reported in GSTR 9of FY 2024-25 or FY 2025-26?

This RCM Liabilities and ITC on said RCM transaction should be reported in GSTR-9 of FY 2025-26.

 

Explanation- As clarified by CBIC vide Press release dated 3rd July 2019, the RCM Liability may be reported in the year, in which it was paid along with applicable interest (if any). Relevant extract of the said press release –

 

g) Reverse charge in respect of Financial Year 2017-18 paid during Financial Year 2018-19: Many taxpayers have requested for clarification on the appropriate column or table in which tax which was to be paid on reverse charge basis for the FY 2017-18 but was paid duringFY2018-19.It may be noted that since the payment was made during FY 2018-19,the input tax credit on such payment of tax would have been availed in FY2018-19 only. Therefore, such details will not be declared in the annual return for the FY2017-18 and will be declared in the annual return for FY 2018-19. If there are any variations in the calculation of turnover on account of this adjustment, the same may be reported with reasons in the reconciliation statement (FORM GSTR-9C).

2 Ineligible ITC of 23-24, availed in FY24-25 (Table4A5 of GSTR 3B) and same was reversed in FY 24-25 (Table 4B1 of GSTR 3B).

 

According to instructions of GSTR 9, we have to report ITC availed of last year FY 2023-24 in Table 6A1 of GSTR 9 of FY 2024-25 i.e. I can report ineligible ITC availed in Table 6A1 but there is no mention of how to show ITC of 23-24 reverse in 24-25 in table 7.

The ITC claimed for FY2023-24 in the FY2024-25 needs to be reported in 6A1.

 

However, ITC reversal of FY2023-24, reported in GSTR3B for FY 2024-25, need not to report in the Table 7 of GSTR 9of FY 2024-25.

 

Table6B to table 6 Hand Table7 A totable7H will contain the details of ITC for the current year only (2024-25).

3 Table 12B of GSTR-9C for FY 2024-25 becomes reductant as Table 7J of GSTR 9 of FY 2024-25doesnotconsiderthe ITC of FY 2023-24 claimed or reversed in FY 24-25 Table12B capture the ITC booked in earlier FY and claimed in current FY. Therefore, this amount will neither appear in Table 12A nor in Table 12E.Hence it appears that this FY, this may create a mismatch.

However, in case of any differences in Table 12F of GSTR 9C, tax payer may provide the reason for un-reconciled differences in ITC in Table 13 of GSTR 9C.

4 Table7J of GSTR9 does not consider 6A1 and therefore

The amount in Table 7J does not match with the Table4C of GSTR 3B of FY 2024-25,

Table 4C of GSTR 3B may contain the ITC of FY 2023-24 claimed or reversed in FY2024-25. However, the Table7J of GSTR9 shows the Net ITC pertaining to the current FY only (2024-25). Therefore, it may create differences between Table4C of GSTR3B and Table 7J Of GSTR9,in cases where ITC of preceding FY(2023-24) was reported in GSTR 3B of current FY (i.e. 2024-25).
5 Can you guide whether ITC reversed during 24-25 pertaining 23-24, how to disclose the same in GSTR-9? whether it is to be reduced from Table 6A1 of GSTR-9 or table7 or should not be shown at all? ITC pertaining to 2023-24 which has been reversed in GSTR 3B of 2024-25 then such reversal will not be reported anywhere in GSTR9 of FY2024-25 as you need to report the reversal of ITC pertaining to current FY only in Table 7 of GSTR 9 for FY 2024-25.
6 ITC of FY 23-24 showing in 2B of FY 2023-24, but goods received in April 2024 i.e. FY 24-25 so ITC claimed in 3B of FY 24-25 which we need to report in 6A1 of FY 24-25.

So ideally it shouldn’t be reported in Table 12B of GSTR 9C as there will be no unreconciled difference but if such ITC is taken in the books in FY2024-25 instead of FY T2-023-24 then 12A of 9C will be high and 12E auto-populated from 7J of 9 will be less and there will be unreconciled difference in 12F for which we should give reasons or how to show this unreconciled

difference?

ITC which pertain to FY 23-24 should not form part of Audited financial statement of 24-25. However, apparently the ITC amount as reported in Audited Financial Statement depends upon methodology adopted by taxpayer.

 

Accordingly, the value in Table 12A to 12C of GSTR 9C may be reported as per the accounting methodology adopted by taxpayer. However, if in case of any differences in the Table 12F of GSTR 9C, taxpayer may provide the reason for un-reconciled differences in ITC in Table 13 of GSTR 9C.

7 Where is non-GST purchase reported in GSTR 9? As there is no specified table in the notified Form GSTR9, for reporting the Non-GST Purchase hence not required to be reported in the GSTR 9.
8 Whether Table 4G1 of GSTR 9 to be reported by ecommerce operator only? Table 4G1 of GSTR 9 to be reported by e commerce operator liable to pay the Tax under section 9(5) of CGST Act.

Disclaimer:

This publication contains information for general guidance only. It is not intended to address the circumstances of any particular individual or entity. Although the best of endeavour has been made to provide the provisions in a simpler and accurate form, there is no substitute to detailed research with regard to the specific situation of a particular individual or entity. We do not accept any responsibility for loss incurred by any person for acting or refraining to act as a result of any matter in this publication.

(Author is a well known Chartered Accountant practicing on direct and indirect taxes)

Leave a Reply

Your email address will not be published. Required fields are marked *

error: Content is protected !!