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
If you have been told your FY 2025-26 Input Tax Credit must be claimed in the September 2026 return, that advice is running on a rule that stopped applying more than four years ago. For FY 2025-26, the ITC cut-off is 30 November 2026 — or the date you file your GSTR-9 annual return for that year, whichever is earlier.
Legal basis: Section 16(4), CGST Act, 2017, as substituted by the Finance Act, 2022 (s.100), notified through Notification No. 18/2022–CT dated 28.09.2022, w.e.f. 01.10.2022; Section 16(2), CGST Act, 2017.
What Section 16(4) actually says
"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 thirtieth day of November following the end of financial year to which such invoice or debit note pertains or furnishing of the relevant annual return, whichever is earlier" (CGST Act, s.16(4)).
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 return's due date. The substitution — "Substituted vide sec 101 of The Finance Act, 2022 (No. 6 of 2022), notified through Notification No. 18/2022–CT dated 28.09.2022, w.e.f. 01.10.2022" — replaced that with the 30-November-or-GSTR-9 test from 1 October 2022. Any advice still anchored to the September return is applying repealed law.
Who this affects
The November 30 rule applies to all regular 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.
- File quarterly and assume the quarterly 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 closes the window early. If GSTR-9 for FY 2025-26 is filed in mid-November 2026, the ITC cut-off for that year moves to that filing date — any FY 2025-26 credit not yet claimed as of that date is lost.
Recommended sequence:
- Complete FY 2025-26 GSTR-2B reconciliation and supplier follow-ups by October 2026.
- Claim all verified ITC in a GSTR-3B furnished on or before 30 November 2026. For monthly filers that is the October 2026 return (due 20 November); the November return falls after the cut-off.
- File GSTR-9 for FY 2025-26 only after the November GSTR-3B is filed.
Practical steps before November 30, 2026
- Reconcile GSTR-2B against your purchase register for April 2025 through the latest filed period, now.
- Identify invoices missing from GSTR-2B and get suppliers to file or amend their GSTR-1 before the relevant cut-off.
- Claim all reconciled ITC in a return furnished on or before 30 November 2026 (for monthly filers, the October 2026 GSTR-3B).
- Hold off on filing GSTR-9 for FY 2025-26 until all eligible ITC has been claimed.
- Confirm the Section 16(2) conditions alongside the deadline: "he is in possession of a tax invoice or debit note issued by a supplier registered under this Act"; "the details of the invoice or debit note referred to in clause (a) has been furnished by the supplier in the statement of outward supplies and such details have been communicated to the recipient"; and "he has received the goods or services or both" (CGST Act, s.16(2)(a), (aa), (b)). A credit claimed in time but failing these conditions is still deniable.
For advice on a specific ITC position, contact a Chartered Accountant.
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