GST input tax credit for 2025-26: the 30 November 2026 cut-off under section 16(4), and the supplier-side limits on the same date

Input tax credit on an invoice or debit note of 2025-26 cannot be taken after 30 November 2026, or after the date on which the annual return for 2025-26 is furnished, if that comes first. The same cut-off governs three corrections on the supplier’s side: declaring credit notes, rectifying the details of outward supplies, and rectifying the return. The following sets out the provisions, how the date works in practice, and what remains to be done in the weeks before it.

The provision and its history

Section 16(4) of the Central Goods and Services Tax Act, 2017 (CGST Act), as originally enacted, tied the time limit to the return:

A registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services or both after the due date of furnishing of the return under section 39 for the month of September following the end of financial year to which such invoice or invoice relating to such debit note pertains or furnishing of the relevant annual return, whichever is earlier.

Section 100(b) of the Finance Act, 2022 substituted “thirtieth day of November” for the reference to the September return. Notification No. 18/2022-Central Tax dated 28 September 2022 brought sections 100 to 114 of that Act into force from 1 October 2022, except clause (c) of section 110 and section 111. The limit is therefore now a calendar date: credit for 2025-26 is barred after 30 November 2026, or after the 2025-26 annual return is furnished, whichever is earlier.

The provision has two limbs. The second is easily overlooked. A taxpayer that furnishes the annual return for 2025-26 before 30 November closes its own window on that day. Any credit still unclaimed when the annual return goes in is lost, even though the calendar date has not arrived. The annual return should be filed only after the credit review for the year is complete.

Which return carries the credit

Credit is taken through the return, so the question in practice is which return can still carry 2025-26 credit. The October 2026 GSTR-3B, due on 20 November, is the last monthly return that falls before the cut-off. The return for November is filed in December, after 30 November, and cannot carry 2025-26 credit.

Section 16(4) speaks of taking credit “after” 30 November. A credit that is still missing when the October return is filed has no later return before the cut-off to carry it. The review of 2025-26 credit therefore has to be finished before the October GSTR-3B is filed; 30 November is too late to begin it.

Credit must also be available in the statement

The time limit is not the only condition. Section 16(2) still applies to each claim. Its conditions include a tax invoice or debit note, receipt of the goods or services, tax actually paid to the Government, and the return under section 39 furnished. The Finance Act, 2022 also inserted clause (ba) in section 16(2): the credit must not have been restricted in the details communicated to the recipient under section 38. Section 38, as substituted by the same Act, provides for an auto-generated statement of input tax credit, which separates credit that may be available from credit that cannot be availed.

Credit that does not appear in that statement cannot be rescued by the date alone. For 2025-26 invoices still missing from the statement, the supplier has to report them. A supplier reporting an omitted 2025-26 invoice in its October GSTR-1, due on 11 November (13 November for B2B invoices furnished through IFF under the quarterly scheme), puts it into the recipient’s October statement. An invoice reported only in the November GSTR-1 reaches the November statement, which is after the cut-off.

Where the supplier has already filed the October GSTR-1 without the invoice, an amendment through GSTR-1A is possible after GSTR-1 and before the supplier files its GSTR-3B for the month. Whether a late amendment reaches the recipient’s October statement in time is a matter of timing, so suppliers should be contacted about missing invoices now, not in the third week of November.

The supplier side: credit notes and rectification

The Finance Act, 2022 moved three other limits to the same date.

Credit notes, section 34(2). A supplier declares a credit note in the return for the month in which it is issued, but not later than 30 November following the end of the financial year in which the supply was made, or the date of furnishing of the relevant annual return, whichever is earlier (section 102 substituted “the thirtieth day of November” for “September”). A credit note for a 2025-26 supply that misses this limit cannot be used to adjust the supplier’s tax liability. Year-end rate differences, returns and settlements on 2025-26 supplies need to be documented and declared by then.

Details of outward supplies, section 37(3). Under the first proviso, no rectification of an error or omission in the details of outward supplies is allowed after 30 November following the end of the financial year to which the details pertain, or the annual return, whichever is earlier (section 103). A wrong GSTIN, a wrong place of supply or an invoice reported in the wrong form for 2025-26 must be corrected by then. After the cut-off, the recipient’s credit on that invoice depends on a correction that can no longer be made.

Returns, section 39(9). The proviso now bars rectification of an omission or incorrect particulars in the return after 30 November following the end of the financial year, or the actual date of furnishing of the relevant annual return, whichever is earlier (section 105). Section 39(9) itself excludes omissions noticed as a result of scrutiny, audit, inspection or enforcement activity, so the proviso governs omissions the taxpayer discovers on its own.

Reconciling before the October return

The work before the October GSTR-3B is the reconciliation of the purchase register with the Invoice Management System (IMS) and GSTR-2B. It produces two lists.

In the books, not in the statement. These need supplier action: reporting in the October GSTR-1, or an amendment through GSTR-1A. Each supplier with outstanding 2025-26 invoices should receive the list of invoice numbers and amounts, not a general request.

In the statement, not in the books. Either the invoice has not reached accounts, in which case the tax invoice should be obtained so that clause (a) of section 16(2) is met, or it does not belong to the taxpayer at all, in which case it should be rejected on IMS.

The exercise should be run now and repeated once the October GSTR-2B is generated, around mid-November. The second run catches invoices that suppliers report in their October statements in response to the first.

Two categories deserve a separate pass. On reverse charge purchases, the timing of the self-invoice and of the tax payment affects the period of the credit, so they should be checked apart from the supplier-side reconciliation. Debit notes, and credit that was earlier reversed, should be listed apart from ordinary invoices. Whether a later claim of reversed credit is a fresh claim subject to section 16(4), or a re-availment under the provision that required the reversal, depends on why it was reversed, and the basis should be recorded.

What section 16(4) does not decide

The 30 November date is an outer limit, not an entitlement. Meeting it does not make an ineligible credit eligible, and an otherwise genuine purchase does not save a credit claimed after it. The two questions are separate, and both arise on every 2025-26 invoice still unclaimed.

Section 16(5) and section 16(6), inserted by the Finance (No. 2) Act, 2024, give relief only in specified situations: section 16(5) for 2017-18 to 2020-21, and section 16(6) for registrations cancelled and later restored. Neither is a general extension, and neither helps an ordinary taxpayer with 2025-26 credit.

This article is intended for educational purposes only and should not be construed as professional advice. It is based on the law as understood on the date of publication; laws and regulations are subject to change, and it may not reflect later developments. Readers are advised to consult a qualified tax professional on their specific situation before taking any action based on it. CA. Mohit Gaba takes no responsibility for any action taken or decision made on the basis of this article.