GST liability for service providers

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This query is : Resolved

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A contractor who obtained GST registration in March 2026 cannot generally issue revised GST invoices for services provided before the effective registration date. For the pre-registration period, only normal invoices without GST are valid, limiting the service recipient's GST liability.

Amit

Amit (Querist)

12 May 2026 My client engaged a contractor who issued non-GST invoices for the period October 2025 to February 2026. In March 2026, the contractor obtained GST registration and subsequently raised GST-compliant invoices covering the entire period from October 2025 to March 2026. Given that no formal contract exists between my client and the contractor, I seek guidance on how my client can avoid liability for GST payment in respect of the period (October 2025 to March 2026).

Dhirajlal Rambhia

Dhirajlal Rambhia

(Expert)

13 May 2026 Under Section 31(3)(a) of the CGST Act, a newly registered person can only issue "Revised Tax Invoices" for supplies made between the effective date of registration and the date of issuance of the registration certificate. Check the contractor’s GST Registration Certificate (Form REG-06). If the contractor's "effective date of registration" is set as a date in March 2026 (the date they applied/registered), they cannot legally issue revised tax invoices for the previous months (October 2025 to February 2026).

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Amit

Amit (Querist)

13 May 2026 Thanks Sir, Can the service provider contend that, since he had previously indicated a tax invoice would be issued, the client is liable for GST—even though the GST registration was only obtained in March 2026?

Dhirajlal Rambhia

Dhirajlal Rambhia

(Expert)

13 May 2026 Before GST registration the supplier has to issue invoice, but cannot charge GST. Only after registration in MARCH he is liable to issue TAX invoice with GST. For service recipient both the invoices are equivalently valid,

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