This is to apprise you of a recent advisory dated 7 June 2025, introduced on the GSTN portal, which proposes the implementation of hard locking of auto-populated liability in GSTR-3B, effective from July 2025 tax period.
Background
As you may be aware, multiple advisories have been issued over the past
months regarding the hard locking of values in GSTR-3B. Below is a summary of
the advisories for your quick reference:
- October 2024: GSTN announced that the auto-populated
values in GSTR-3B would be hard locked (both outward supplies and input
tax credit), tentatively from January 2025 tax period.
- January 2025: Following industry
representations, GSTN deferred the implementation to allow taxpayers
additional time to adapt to the change.
- April 2025: GSTN proposed hard
locking of auto-populated values in Table 3.2 of GSTR-3B
(inter-state supplies to unregistered persons, composition taxpayers, and
UIN holders), effective from April 2025 tax period.
- May 2025: In response to various
representations from taxpayers, GSTN deferred the implementation of hard
locking and allowed the auto-populated values in Table 3.2 of GSTR-3B to
remain editable.
Current Mechanism w.r.t reporting of tax liability in GSTR-3B, till June
2025 tax period
- After reporting outward supplies in GSTR-1/IFF,
taxpayers can amend these details through Form GSTR-1A within the same
return period for corrections, if any.
- The tax liability in GSTR-3B is auto-populated
based on the outward supplies declared in GSTR-1, IFF, and GSTR-1A.
- However, till June 2025 tax period, taxpayers can
edit such auto-populated values in GSTR-3B prior to filing the
return.
Key change w.r.t reporting of tax
liability in GSTR-3B, from July 2025 tax period
- The hard locking of GSTR-3B, which was previously
deferred in January 2025, is now proposed for
implementation from July 2025 tax period (returns due in August 2025), in
relation to auto-populated liability, from GSTR-1/IFF/GSTR-1A, in GSTR-3B.
- From July, 2025 tax period onwards,
auto-populated liability in GSTR-3B will become non-editable. Accordingly,
any corrections to GSTR-1 will be required to be made through Form GSTR-1A
before filing GSTR-3B.
- If errors in GSTR-1 are not identified and
corrected via GSTR-1A before filing GSTR-3B, the liability cannot be
adjusted in the same month. The liability will then be required to be
reported in the subsequent month, potentially attracting interest, if any,
due to delayed reporting.
Comments
Outward tax liability
- This change aims to reduce mismatches in tax
liability reporting between GSTR-1 and GSTR-3B.
- Since the figures as reported in GSTR-1 can be
amended via GSTR-1A (before filing of GSTR 3B), hard locking of figures in
GSTR 3B should not be an issue. However, timely and accurate amendments
are crucial, as GSTR-1A currently does not allow multiple filings.
Further, discrepancies in GSTR-1 should be identified well in advance to
avoid a scenario where there is insufficient time to file GSTR-1A
Input tax credit
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