Finance/Compliance Consultant
77731 Points
Posted on 06 November 2026
The time limit has now passed for July 2023 invoices:
• Sec 37(3) / 39(9): missing invoices of FY 2023-24 could be reported (or amended) up to 30 November 2024. That window is closed, so the portal will not accept July 2023 invoices in a current GSTR-1.
• Your liability: if the tax on these invoices was not paid in GSTR-3B, pay it now through DRC-03 (voluntary, Sec 73(5)), with interest at 18% (Sec 50) from the due date. If it was already included in 3B, there is no tax shortfall, only a GSTR-1 reporting gap. Explain it in GSTR-9/9C (Table 10/11 adjustments may also be closed for FY 2023-24).
• Buyer's ITC: since the invoices never appeared in their GSTR-2B and the Sec 16(4) deadline (30 November 2024) has passed, the buyer cannot claim the ITC. Commercially, they may ask you to bear the tax or issue a credit note.
• Also note the 3-year bar on filing returns (Sec 37(5) / 39(11), from July 2025). Old periods can no longer be filed.
• Prevention: run a monthly GSTR-1 vs books vs e-invoice/IRP reconciliation.