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For invoices and debit notes belonging to FY 2025-26, the ordinary Section 16(4) deadline to claim GST input tax credit (ITC) is 30 November 2026 or the date you furnish the relevant annual return, whichever is earlier. The credit must be included in a qualifying Section 39 return that is actually furnished by the controlling date. A later-period GSTR-3B does not automatically preserve the claim, so reconcile every document, resolve supplier mismatches and complete statutory checks before filing.
What is the statutory last date for FY 2025-26 ITC?
Section 16(4) sets the outer limit at the thirtieth day of November following the end of the financial year. For FY 2025-26, that date is 30 November 2026. If the relevant annual return is furnished earlier, its filing date becomes the earlier cut-off.
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Retrospective relief discussed in Circular 237/31/2024-GST concerns specified earlier financial years under Sections 16(5) and 16(6). It should not be treated as a general extension for FY 2025-26 unless a later official amendment expressly says so.
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Which eligibility tests apply to every invoice or debit note?
A line appearing as available in GSTR-2B is not, by itself, proof that the credit is legally claimable. Test each document against all of the following conditions:
- You possess a valid tax invoice, debit note or other prescribed tax document.
- The supplier has furnished and communicated the document details through the GST system.
- The goods or services have actually been received.
- The related tax has been paid to the Government.
- You have filed the required return.
- Where applicable, the supplier has been paid within the 180-day condition. A shortfall can require reversal with interest, followed by re-availment after payment.
- No blocked-credit, restriction or other reversal rule applies. GSTN states that not every legal restriction is fully represented in GSTR-2B, so self-assessment remains necessary.
How do I reconcile FY 2025-26 ITC invoice by invoice?
Use a controlled population, a consistent document key and an exception log. The following sequence keeps accounting records, statements and legal tests aligned.
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- Freeze the population. Export the FY 2025-26 purchase register and gather invoices, debit notes, credit notes, amendments, reverse-charge documents, ISD documents and import bills of entry. Mark the financial year and document type used for the Section 16(4) test.
- Create a document key. Match supplier GSTIN, document number, document date, taxable value and each tax component. Link amendments and credit notes to the original document so a revised invoice is not counted twice.
- Download every applicable GSTR-2B. GSTN describes GSTR-2B as a read-only, auto-drafted ITC statement used to prepare GSTR-3B. It is generated monthly for monthly recipients and quarterly for quarterly recipients. Preserve each Excel or JSON download together with its generation period.
- Match status and amount. Compare purchase-register rows with GSTR-2B rows, including supplier corrections and amendments. Investigate missing or duplicate records, an incorrect GSTIN, wrong place of supply and taxable-value or tax differences. Because the recipient cannot edit GSTR-2B, the usual remedy is supplier correction followed by inclusion in a later open statement.
- Use the Invoice Management System (IMS) deliberately. Accept genuine records, reject records that do not belong to you or are materially erroneous, and leave genuinely unresolved items pending. No-action records are generally deemed accepted when GSTR-2B is generated. After changing an action, recompute the statement before filing GSTR-3B when required.
- Run the statutory tests. For every candidate credit, verify document possession, supplier reporting and communication, receipt, tax payment, return filing, the 180-day payment rule and blocked-credit provisions. Do not substitute a positive statement line for these checks.
- Separate special streams. Reconcile reverse-charge entries to evidence of tax payment, ISD credits to the relevant GSTR-6 trail and import IGST to bills of entry and ICEGATE records. These streams appear in distinct sections or evidence paths and should not be mixed with ordinary supplier invoices.
- Prepare and furnish the return. Enter eligible ITC in the appropriate GSTR-3B fields, post required reversals, review system-populated values and sign off an exception log. Confirm that the final return has actually been furnished by the statutory cut-off.
How does monthly filing differ from QRMP filing?
Your filing cycle determines which return can carry the credit and when supporting statement data becomes available.
| Filer | Statement pattern | Planning action |
|---|---|---|
| Monthly GSTR-3B filer | GSTR-2B is generated each month. | Identify the last monthly return that can be furnished by the Section 16(4) cut-off and finish reconciliation before that filing. Verify the portal’s current due date because notifications can change it. |
| QRMP or other quarterly filer | GSTR-2B is quarterly; QRMP taxpayers do not receive monthly GSTR-2B for the first two months of a quarter. | Map each FY 2025-26 document to the last quarterly return that can actually be furnished by the statutory date, allowing time for supplier corrections and statement generation. |
| Annual return filed early | The annual return date can be earlier than the ordinary November cut-off. | Treat the actual annual-return filing date as the controlling Section 16(4) limit. |
What does GSTR-2B decide, and what does it not decide?
GSTR-2B is read-only and auto-drafted; it supports GSTR-3B preparation but cannot be edited by the recipient. Its Table 4 includes invoices and debit notes identified as ineligible under Section 16(4), which flow to GSTR-3B Table 4D(2).
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GSTR-2B does not replace your books or legal review. Reconcile it to the purchase register, prevent duplicate claims, reverse credit required by law and pay reverse-charge tax before claiming the related credit. Restrictions that are not fully represented in the statement must be identified and handled by the taxpayer.
How should I handle IMS accept, reject and pending records?
IMS status affects what is available for statement generation and GSTR-3B auto-population, so use each status for a defined reason.
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| Status | Use it when | Effect and follow-up |
|---|---|---|
| Accept | The record belongs to you and passes your initial document review. | It enters the available section and eligible GSTR-3B auto-population; still complete all Section 16, payment and blocked-credit tests. |
| Reject | The record is not yours or is materially erroneous. | It does not enter the available section. Retain the reason and request supplier correction where appropriate. |
| Pending | You need clarification or evidence before deciding. | It remains available for later action and should not be treated as cleared merely because it is visible. |
| No action | You have not acted before statement generation. | It is generally deemed accepted at GSTR-2B generation; review the resulting statement and recompute after any later action when necessary. |
For material decisions, retain screenshots or exported IMS logs showing the record, action and date.
What should I check before furnishing the final GSTR-3B?
- Every FY 2025-26 invoice and debit note has a unique key and an identified statement or evidence source.
- Amendments, credit notes and reversals are linked to the original document and cannot create a duplicate claim.
- Supplier mismatches, wrong GSTINs, place-of-supply errors and value differences have a documented resolution or exclusion.
- RCM tax has been paid before claiming the associated ITC; ISD and import entries agree with their separate records.
- 180-day payment issues, blocked credits and other reversals are posted in the correct period.
- System-populated GSTR-3B values agree with the reviewed working papers.
- The return is furnished, not merely prepared or saved, by the controlling Section 16(4) date.
What happens if a supplier corrects an invoice after my first reconciliation?
Download the next applicable GSTR-2B, link the corrected row to the original document key and remove any superseded or duplicate line. If you changed an IMS action, recompute the statement before filing the affected GSTR-3B and preserve the before-and-after evidence.
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Frequently Asked Questions
Can I claim FY 2025-26 ITC in a November 2026 GSTR-3B?
Yes, if the credit satisfies every Section 16 condition and the GSTR-3B containing it is actually furnished by the applicable cut-off. A draft, saved return or later filing does not protect the claim.
Do QRMP taxpayers get GSTR-2B every month?
No. QRMP recipients receive a quarterly GSTR-2B, so the first two months of a quarter do not provide a monthly statement for reconciliation. Plan supplier follow-ups and document matching around the quarterly generation cycle.
What records should I retain for an ITC audit?
Keep the purchase register, source tax documents, each downloaded GSTR-2B file with its generation period, supplier correspondence, payment evidence, import or ISD records, IMS screenshots or exports and the signed exception log. These show both the eligibility analysis and the filing trail.
What if an amount is visible in GSTR-2B but later turns out to be blocked credit?
Exclude or reverse it according to the applicable GST rule, even if the statement labels it available. GSTR-2B is an information and preparation statement, not a waiver of the recipient’s duty to self-assess restrictions.
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