Finance/Compliance Consultant
77979 Points
Posted on 06 November 2026
Adding the law and the practical options:
• Sec 17(4) read with Rule 44(4): when goods become wholly exempt, ITC on inputs held in stock (and in semi-finished or finished goods) on the day before the exemption must be reversed. File FORM GST ITC-03 within 30 days, through cash or credit ledger.
• The reversed 5% becomes part of the inventory cost. There is no refund route, because exempt supplies are not zero-rated and inverted-duty refund (Sec 54(3)) does not apply to exempt outputs.
• Recovery is commercial: (a) negotiate a credit note or price adjustment with the supplier for unsold stock bought just before 22 September 2025; (b) reprice. The anti-profiteering principle applies to rate cuts, not to absorbing a reversal.
• Going forward:
– Purchases of these goods carry GST you cannot claim, so negotiate a lower purchase price.
– Common inputs and services must be apportioned between taxable and exempt supplies under Rule 42/43, with an annual true-up in September's GSTR-3B.
– If all your supplies are now exempt, cancel registration (Sec 29) and pay ITC on remaining stock and capital goods in REG-16/GSTR-10.