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GST

GSTR-3B Table 4 ITC Locked from July 2026: What You Must Do

From July 2026, manual editing of ITC in GSTR-3B Table 4 is no longer allowed. Your eligible ITC is now auto-populated from GSTR-2B, which reflects only invoices your suppliers have filed in GSTR-1 and you have accepted via the Invoice Management System. Missing or rejected invoices mean no ITC claim—until suppliers file.

CH

CA Harun Raaj

Chartered Accountant · Harun Raaj & Associates

Legal basis: Section 38, CGST Act, 2017 (substituted w.e.f. 1 October 2025 by CBIC Notification No. 16/2025-Central Tax, dated 17 September 2025); Section 16(2)(aa), CGST Act), 2017 (inserted by Finance Act 2022, effective 1 October 2022); Rule 60, CGST Rules, 2017 — Effective: July 2026 tax period onwards (Phase 2 hard-lock). Source: GSTN Advisory No. 606 and CBIC circulars; https://www.taxscan.in/top-stories/big-gst-change-from-july-2026-gstr-3b-itc-locking-explained-1448389. Last reviewed by CA Harun Raaj: December 2024.

From July 2026, you can no longer manually edit eligible ITC in Table 4A(3) of GSTR-3B. The GST Network (GSTN) has hard-locked this table to auto-populate exclusively from GSTR-2B, the auto-generated eligible ITC statement. This is Phase 2 of a systematic return-locking initiative—Phase 1 locked Table 3 (outward tax liability) from July 2025.

The practical consequence is direct: your ITC eligibility now depends entirely on what your suppliers file in GSTR-1 and what you accept (or do not reject) in the Invoice Management System (IMS). If a supplier has not filed their GSTR-1, or if you have rejected their invoice in IMS, that credit is not available in GSTR-3B—no manual override is possible.

Key point: From July 2026, your eligible ITC in GSTR-3B Table 4A(3) is locked to what appears in GSTR-2B; invoices missing from GSTR-2B cannot be manually claimed and must wait for future supplier filing or acceptance.

How IMS Controls Your ITC Eligibility

The Invoice Management System (IMS), mandatory for regular taxpayers from 1 April 2026, is a dashboard on the GST portal where every B2B invoice your suppliers file in GSTR-1 appears. You take one of three actions on each invoice:

ActionAppears in GSTR-2B?ITC Claimable in Table 4A(3)?
Accept (or take no action—deemed accept after 30 days)YesYes
RejectNoNo
PendNo (deferred to next period)No, until you accept it

Because Table 4A now pulls directly from GSTR-2B, an invoice that is absent from GSTR-2B—whether because the supplier never filed GSTR-1, or because you rejected it in IMS—will not appear as eligible ITC in your return. You cannot manually add it.

The Two-Phase Hard-Lock Timeline

PhaseEffective FromTable AffectedAuto-Populated FromAdvisory/Notification
Phase 1July 2025Table 3 (outward tax liability)GSTR-1 filed by all suppliersGSTN Advisory No. 606
Phase 2July 2026Table 4A(3) (eligible ITC)GSTR-2B via IMS actionsCBIC Notification No. 16/2025-Central Tax (17 Sep 2025)

What Remains Editable in Table 4

You retain manual control over three sub-tables:

  • Table 4A(2): Reverse Charge Mechanism (RCM) ITC. GSTR-2B may not capture RCM invoices; you declare these manually.
  • Table 4B: ITC reversals under Rule 37 (invoices unpaid beyond 180 days) and Rule 42/43 (capital goods adjustments).
  • Table 4C: Ineligible ITC blocked under Section 17(5)—motor vehicles, personal consumption, non-business goods, and other statutorily excluded supplies.

Real-World Impact: What Happens in July 2026

Consider an IT services firm in Bengaluru with ₹3.2 crore annual turnover. In June 2026, the firm receives software subscriptions from 8 vendors. Two vendors have not filed their June GSTR-1 by 11 July 2026. Previously, the accountant could manually claim ₹35,000 ITC for those two vendors in the June GSTR-3B. From July 2026, those invoices are absent from GSTR-2B. Table 4A(3) reflects only the ITC from the 6 compliant vendors. The ₹35,000 cannot be manually entered—it must wait until those vendors file GSTR-1 and the invoice re-appears in a future GSTR-2B, subject to the annual ITC eligibility cut-off.

Critical timing: FY 2025–26 ITC must be claimed by the earlier of (a) the due date for September 2026 GSTR-3B (typically 20 October 2026), or (b) the date you file GSTR-9 for FY 2025–26. After this deadline, unclaimed ITC is permanently lost under Section 16(4).

Essential Checklist for Your July 2026 GSTR-3B Filing

  • IMS Dashboard Review: Open the GST portal IMS dashboard and action all pending invoices from June 2026. Ensure you have accepted (or not rejected) all expected B2B invoices.
  • GSTR-2B Reconciliation: Check your auto-generated GSTR-2B (typically available by 14 July 2026). Cross-reference your purchase books to identify any missing invoices.
  • Supplier Follow-Up: Contact suppliers whose invoices are missing from GSTR-2B. Request them to file GSTR-1 or correct via GSTR-1A (amended GSTR-1).
  • RCM Declaration: Manually enter RCM ITC in Table 4A(2) with full supporting documentation.
  • 180-Day Payment Rule: Review invoices in your books. Reverse ITC in Table 4B for any invoices unpaid beyond 180 days (Rule 37, CGST Rules, 2017).
  • Section 17(5) Blocked Credits: Identify and declare ineligible supplies (motor vehicles, personal use, etc.) in Table 4C.
  • FY Cut-Off Deadline: Mark the due date for September 2026 GSTR-3B on your calendar. Any FY 2025–26 ITC not claimed by this date is permanently forfeited.

I'm CA Harun Raaj, Visakhapatnam. If your business is affected by this July 2026 change or you need support with IMS management and GSTR-3B compliance, reach out to discuss your GST strategy.

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See Also

Frequently Asked Questions

Can I claim ITC for an invoice in my books that does not appear in GSTR-2B?+

No. From July 2026, Table 4A(3) is auto-populated from GSTR-2B only. If an invoice is not in GSTR-2B—because the supplier has not filed GSTR-1 or you have rejected it in IMS—it cannot be claimed. The supplier must file or amend GSTR-1 (via GSTR-1A), and the invoice must appear in a future GSTR-2B before you can claim ITC, subject to the Section 16(4) annual cut-off.

What happens if I accidentally reject an invoice in the IMS?+

Once you file GSTR-3B, IMS actions for that period are locked. The supplier can correct via GSTR-1A, and the invoice may appear in a future GSTR-2B. However, all ITC for FY 2025–26 must be claimed by the earlier of the due date for September 2026 GSTR-3B (typically 20 October 2026) or your GSTR-9 filing date. After this, the credit is permanently lost under Section 16(4).

Does the GSTR-3B Table 4 hard-lock apply to composition scheme taxpayers?+

No. Composition scheme taxpayers do not file GSTR-3B and are not required to use IMS. This Phase 2 change applies only to regular scheme taxpayers.

When is the last date to claim all FY 2025–26 ITC?+

The earlier of: (a) the due date for September 2026 GSTR-3B (typically 20 October 2026); or (b) the date you file GSTR-9 for FY 2025–26. After this deadline, unclaimed FY 2025–26 ITC is permanently lost under Section 16(4), CGST Act.

Our supplier is a QRMP quarterly filer. When will their invoices appear in GSTR-2B?+

If the supplier uses the Invoice Furnishing Facility (IFF), invoices appear monthly. If not, all three months of invoices in a quarter appear together in the quarterly GSTR-2B only at quarter-end.

Can I manually claim RCM ITC in Table 4A(2) if it does not appear in GSTR-2B?+

Yes. Table 4A(2) (RCM ITC) remains manually editable because GSTR-2B may not capture reverse charge invoices. You must declare RCM supplies manually in Table 4A(2) with full supporting documentation.

What is the 180-day payment rule for ITC reversal in Table 4B?+

Under Rule 37, CGST Rules, if an invoice remains unpaid beyond 180 days, you must reverse its ITC in Table 4B of your GSTR-3B. Once the invoice is paid, you can reclaim the ITC in the subsequent return, subject to the annual cut-off under Section 16(4).

How do I check if all my supplier invoices are in IMS?+

Log into the GST portal, open the IMS dashboard, and review all invoices from your suppliers for the relevant period. Cross-reference these against your purchase register. Any invoice in your books but missing from IMS means the supplier has not filed GSTR-1 for that invoice yet. Contact the supplier immediately to file or correct via GSTR-1A.

Topics:GSTR-3B Table 4 ITC locked July 2026IMS Invoice Management System GSTGSTR-2B auto-population rulesGST eligible ITC hard lock Phase 2FY 2025-26 ITC cut-off deadlineSection 16(4) GST ITC lapseCBIC Notification 16/2025 GSTR-3B changesGST compliance checklist regular taxpayers

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