GSTN Advisory :To file pending returns before expiry of three years

CA Rakesh Kumar Choudhary September 16, 2025 3 min read 76 Views
GSTN Advisory :To file pending returns before expiry of three years

GSTN has issued a critical advisory stating that taxpayers must file all pending GST returns before the expiry of three years from their respective due dates, as mandated by amendments in the Finance Act, 2023 and implemented via Notification No. 28/2023–Central Tax. Starting from October 1, 2025, the GST portal will permanently bar the filing of any GST return which has crossed this three-year window from its original due date.Below is a tabular summary of the GSTN advisory regarding the filing of pending returns before the expiry of three years:

Particulars Details Example of Period Barred after 1 Oct 2025 Covered Forms
Effective Date Restriction applies from 1 October 2025    
Time Limit for Filing Filing of GST returns not allowed after 3 years from due date Return due June 2022 → Barred after June 2025  
Law/Notification Finance Act, 2023; Notification No. 28/2023 – Central Tax dated 31.07.2023    
Returns/Forms Covered Returns under Sec. 37, 39, 44, 52 of CGST Act   GSTR-1, 3B, 4, 5, 5A, 6, 7, 8, 9, 9C
Barred Period Examples Returns for which 3 years have passed since the due date by 1 Oct 2025 GSTR-1 for June 2022, GSTR-4 for FY 21-22, GSTR-9 for FY 20-21  
Last Filing Opportunity Pending returns must be filed before 30 September 2025 Returns due before September 2022 not allowed post 1 Oct 2025  
Portal Restriction GST portal will block filing after 3 years from due date No exceptions after the deadline  
 

Immediate Steps for Taxpayers

  • Taxpayers should immediately reconcile and file all pending GST returns for periods expiring within the three-year time limit by September 30, 2025.

  • After October 1, 2025, filing these past returns will not be possible under any circumstances, as the portal will lock such options permanently.

Advisory Background and Enforcement

  • Multiple advisories have already been issued by GSTN to create awareness (notably on 29th October 2024 and 9th September 2025); the September 2025 notice is the final, actionable warning.

  • The purpose is to ensure timely compliance and discipline and to avoid endless opportunities for late filings.

    Bottom line: All GST return filers should urgently attend to any old or pending returns about to cross the three-year limit, as no grace period or remedy will be available after the cutoff

 
 
 
 
 
Share this article
CA Rakesh Kumar Choudhary
Chartered Accountant
CA Rakesh Kumar Choudhary

Rakesh Kumar Choudhary,CA,CISA,FCA,CERT (FORENSIC ACCOUNTING AND FRAUD DETECTION),10+ years experience in direct and indirect taxation.