Subject: Guidance Required on Reporting Missed FY 2024–25 B2B Supplies and E-Invoice Non-Issuance.
This query is : Resolved
03 January 2026
Dear Sir/Madam,
We seek your professional guidance on a GST compliance matter, the details of which are outlined below.
We had B2B supplies during FY 2024–25 which were not reported in the relevant GSTR-1 and GSTR-3B for the respective periods. Further, e-invoices were not issued at the time of supply, and the 30-day time limit for e-invoice reporting has since expired.
We now intend to declare these transactions and pay the applicable GST along with interest in the current returns (December-2025 GSTR-3B and GSTR-1). Due to the above constraints, we are considering reporting these transactions as B2C instead of B2B. We also propose to disclose the same in GSTR-9 (Table 10) for FY 2024–25. As B2C Supply.
In this context, we request your advice on the following:
1. What is the correct and legally compliant method to disclose these missed FY 2024–25 supplies at this stage?
2. Considering that the e-invoice was not issued and the prescribed time limit has lapsed, is it permissible to report these B2B supplies as B2C in the December GSTR-1 and GSTR-3B, or would this be regarded as misreporting under GST law?
3. What would be the recommended and safest approach to regularize this matter and minimize exposure to penalties, interest, or future litigation?
We would appreciate your guidance on the appropriate course of action.
Thanking you.
We seek your professional guidance on a GST compliance matter, the details of which are outlined below.
We had B2B supplies during FY 2024–25 which were not reported in the relevant GSTR-1 and GSTR-3B for the respective periods. Further, e-invoices were not issued at the time of supply, and the 30-day time limit for e-invoice reporting has since expired.
We now intend to declare these transactions and pay the applicable GST along with interest in the current returns (December-2025 GSTR-3B and GSTR-1). Due to the above constraints, we are considering reporting these transactions as B2C instead of B2B. We also propose to disclose the same in GSTR-9 (Table 10) for FY 2024–25. As B2C Supply.
In this context, we request your advice on the following:
1. What is the correct and legally compliant method to disclose these missed FY 2024–25 supplies at this stage?
2. Considering that the e-invoice was not issued and the prescribed time limit has lapsed, is it permissible to report these B2B supplies as B2C in the December GSTR-1 and GSTR-3B, or would this be regarded as misreporting under GST law?
3. What would be the recommended and safest approach to regularize this matter and minimize exposure to penalties, interest, or future litigation?
We would appreciate your guidance on the appropriate course of action.
Thanking you.
04 January 2026
Missed FY 2024–25 B2B supplies must still be reported as B2B, even if e-invoices were not issued and the IRN window has expired. Reclassifying B2B as B2C is legally incorrect and high-risk. The safest and compliant solution is to pay GST with interest now, report correctly in current returns, and disclose in GSTR-9 (Table 10). E-invoice non-issuance is a procedural lapse, not a ground for misreporting.
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