ITC Claim Deadline for FY 2025-26: November 30, 2026, Not September GSTR-3B
The Input Tax Credit cut-off for FY 2025-26 is November 30, 2026 — not the September GSTR-3B due date of October 20 — under Section 16(4) of the CGST Act as amended by Finance Act 2022. Businesses still working off the pre-2022 rule risk losing eligible credit, and an early GSTR-9 filing can pull that deadline in even further.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Section 16(4), CGST Act 2017, as substituted by Finance Act 2022 — Effective: 1 October 2022 (per Notification No. 18/2022-Central Tax dated 28 September 2022). Source: https://cbic-gst.gov.in/cgst-act.html. Last reviewed by CA Harun Raaj: September 2026.
If you have been told your FY 2025-26 Input Tax Credit must be claimed in the September 2026 GSTR-3B (due October 20), that advice is running on a rule that stopped applying more than four years ago. For FY 2025-26, the correct ITC cut-off is November 30, 2026 — or the date you file your GSTR-9 annual return for that year, whichever is earlier.
What Section 16(4) Actually Says
Section 16(4) of the CGST Act 2017, as substituted by Finance Act 2022 and in force from 1 October 2022, provides that a registered person cannot take ITC on an invoice or debit note after the thirtieth day of November following the end of the financial year to which the invoice relates, or the date of furnishing the relevant annual return — whichever comes first.
For FY 2025-26 (1 April 2025 to 31 March 2026), that means:
- The outer cut-off is 30 November 2026.
- If GSTR-9 for FY 2025-26 is filed before that date, the cut-off moves to the earlier GSTR-9 filing date.
Key point: Under Section 16(4) of the CGST Act as amended by Finance Act 2022, ITC for FY 2025-26 can be claimed until 30 November 2026 or the GSTR-9 filing date, whichever is earlier.
Before and After Finance Act 2022
The confusion persists because the pre-2022 rule tied ITC to the September GSTR-3B due date, and that habit has not fully died out in practice.
Who This Affects
The November 30 rule applies to all regular (non-composition) GST-registered taxpayers with unclaimed FY 2025-26 ITC, including businesses that:
- Found missed invoices during GSTR-2B reconciliation after September 2026.
- Are waiting on a supplier to file or amend GSTR-1 before the credit appears in GSTR-2B.
- Are on QRMP and assume the quarterly filing cycle changes the time limit — it does not.
The GSTR-9 Early-Filing Trap
Because the cut-off is "30 November or GSTR-9 date, whichever is earlier," filing your annual return too soon can close the window early. If GSTR-9 for FY 2025-26 is filed on, say, 15 November 2026, the ITC cut-off for that year moves to 15 November — two weeks before the statutory outer limit. Any FY 2025-26 credit not yet claimed as of that filing date is lost.
Recommended sequence:
- Complete FY 2025-26 GSTR-2B reconciliation and supplier follow-ups by October 2026.
- Claim all verified ITC in the October or November 2026 GSTR-3B.
- File GSTR-9 for FY 2025-26 only after the November GSTR-3B is filed — ideally in December 2026.
Practical Steps Before November 30, 2026
- Run a full reconciliation of GSTR-2B against your purchase register for April 2025 through the latest filed period, now.
- Identify invoices missing from GSTR-2B and contact suppliers to file or amend their GSTR-1 before the relevant monthly cut-off.
- Claim all reconciled ITC in the October 2026 GSTR-3B (due 20 November) or November 2026 GSTR-3B (due 20 December), keeping the 30 November outer limit in mind.
- Hold off on filing GSTR-9 for FY 2025-26 until all eligible ITC has been claimed.
- Confirm the other conditions under Section 16(2) — valid invoice, receipt of supply, supplier's tax payment, and GSTR-2B appearance — are also satisfied within the window.
I'm CA Harun Raaj, Visakhapatnam. If your FY 2025-26 ITC reconciliation is still open or you are planning your GSTR-9 filing date, reach out before you file.
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See Also
Frequently Asked Questions
What is the ITC claim deadline for FY 2025-26 under Section 16(4) of the CGST Act?
The deadline is 30 November 2026, or the date you file your GSTR-9 annual return for FY 2025-26, whichever is earlier. This follows from Section 16(4) of the CGST Act 2017 as substituted by Finance Act 2022, effective 1 October 2022.
Is the ITC deadline still the September GSTR-3B due date of October 20?
No, that rule applied only up to FY 2021-22, under Section 16(4) as it stood before Finance Act 2022. Since 1 October 2022, the cut-off is 30 November following the financial year, or the GSTR-9 filing date, whichever is earlier.
Can I still claim FY 2025-26 ITC in my October 2026 GSTR-3B?
Yes. The October 2026 GSTR-3B is due 20 November 2026, which falls within the 30 November cut-off under Section 16(4). ITC can also be claimed in the November 2026 GSTR-3B if the invoice appears in your GSTR-2B before you claim it.
Does filing GSTR-9 early affect my ITC claim window for FY 2025-26?
Yes. Section 16(4) sets the cut-off as 30 November or the GSTR-9 filing date, whichever is earlier. If GSTR-9 for FY 2025-26 is filed before 30 November 2026, any unclaimed ITC as of that filing date is lost.
Does the November 30 ITC deadline apply to QRMP filers?
Yes. QRMP filers are subject to the same Section 16(4) time limit as monthly filers; the quarterly filing cycle does not change the 30 November cut-off for the financial year.
My supplier filed their GSTR-1 late — will the ITC still appear in time?
If the supplier files or amends their GSTR-1 before the relevant monthly cut-off ahead of 30 November 2026, the credit will appear in your GSTR-2B in time to be claimed. After that, it will not reflect in GSTR-2B before the Section 16(4) deadline.
What is the ITC deadline for FY 2024-25, and is there any extension?
The Section 16(4) cut-off for FY 2024-25 was 30 November 2025. The draft notes no extension or amnesty scheme for FY 2024-25 ITC had been announced as of the review date.
Besides the timing under Section 16(4), what other conditions must be met to claim ITC?
Section 16(4) governs only the time limit. The credit must also satisfy the conditions under Section 16(2) — a valid invoice, receipt of the supply, the supplier's tax payment, and appearance in your GSTR-2B — all within the claim window.
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