The two deadlines nobody told you about
Vikram opened the GST portal this morning expecting a routine task: GSTR-1 for April 2026 — he has done this eleven times now. His accountant had already WhatsApped “Sir, GSTR-1 today.” He clicked through to the Returns Dashboard and started the April entries. Forty minutes, maybe less.
What Vikram did not notice was a second line on the same dashboard, sitting quietly in the historical-returns section. April 2023. Status: Not Filed.
That return has sat there for three years. Today is the last day anyone can touch it. After today, the portal blocks it permanently — no override, no appeal, and no late-fee payment that can reopen it.
What most businesses are missing right now
Most owners know GSTR-1 is due on the 11th: file outward supplies, generate GSTR-2B for buyers, move on. That is deadline number one — April 2026 GSTR-1, due today.
Deadline number two is quieter. Under Section 37 of the CGST Act, 2017 (as amended by the Finance Act 2022), no GSTR-1 can be filed more than three years after its original due date. For April 2023 that due date was 11 May 2023 — exactly three years ago today. After today the portal will not accept the April 2023 return, for any reason or any amount.
The 3-year lock has been running silently since 2022. March 2023 closed on 11 April 2026; April 2023 closes today; May 2023 will close on 11 June 2026.
What the law actually says
Under Section 37 (as amended by the Finance Act 2022), a registered taxpayer cannot file a GSTR-1 after three years from its original due date. This is not a penalty provision — it is a hard portal block. Once the window closes, the system will not accept the return regardless of the reason for non-filing.
A GSTR-1 is like a shipping manifest sent to a freight exchange: until your manifest arrives, your buyers can’t confirm their cargo. Once you file, their GSTR-2B updates on the 14th and they can claim ITC. If you don’t file, they can’t — and if the portal locks your old return, no invoice or payment record will restore the ITC chain.
| Regulatory event | What it means for your business |
|---|---|
| Section 37 — 3-year portal lock (Finance Act 2022) | April 2023 GSTR-1 (due 11 May 2023) cannot be filed after today — the portal permanently blocks access |
| GSTR-1 for April 2026 due today | Monthly filers above ₹5 crore must file today; late fee ₹50/day from tomorrow under Section 47 |
| Late GSTR-1 blocks buyer ITC | Your buyers cannot claim April 2026 ITC in GSTR-2B (generated 14 May) until you file your GSTR-1 today |
| GSTR-3B now hard-locked from GSTR-1 | From July 2025, GSTR-3B Table 3 is auto-populated from GSTR-1 and cannot be manually overridden — accuracy today is non-negotiable |
What happened to Vikram — and what Priya did differently
Both own mid-sized manufacturing firms in Gurugram, both above ₹5 crore turnover. Both had a difficult April 2023 — a finance-team changeover, vendor disputes, a busy quarter-close — and in both companies the April 2023 GSTR-1 slipped, unnoticed at the time.
- Pulled a historical return-status report before today’s filing
- Found the April 2023 gap and filed it immediately
- Paid the applicable ₹50/day late fee — manageable
- Her buyers’ ITC trail stayed intact
- Filed April 2026 GSTR-1 and closed the laptop
- Missed the April 2023 “Not Filed” line on the dashboard
- ₹14 lakh of B2B invoices will never appear in any GSTR-2B
- No portal-level path to fix an ITC dispute
The difference is not which CA they had. It is whether anyone thought to look backward today before looking forward.
How to start right now — 5 steps
- Check April 2026 GSTR-1 status immediately. gst.gov.in → Returns → Returns Dashboard → April 2026. If not filed, begin now — the portal slows under peak traffic near deadlines.
- Pull a historical return-status check before closing the tab. Returns → View Filed Returns. Check every month from April 2023 onward. Any “Not Filed” from April 2023 is in its final window today; May 2023 and beyond have their own closing dates.
- Contact WeConsult India if any historical return shows unfiled. Don’t backfile without first reviewing the ITC implications, late fees and correct filing sequence. A 30-minute call today could prevent a three-year liability becoming permanent.
- Brief your accountant on the GSTR-3B hard-lock. From July 2025, GSTR-3B Table 3 is auto-populated from GSTR-1 and can’t be manually overridden. Any error in today’s GSTR-1 must be fixed via GSTR-1A before you file GSTR-3B on 20 May.
- Set a reminder for 20 May today. GSTR-3B for April 2026 is due 20 May — and the data you submit in GSTR-1 today directly determines what auto-populates there in nine days.
If both returns are filed correctly, your buyers see clean ITC — and your FY 2026-27 compliance starts on solid ground.
Key takeaways
| Key compliance point | What you must do |
|---|---|
| GSTR-1 for April 2026 is due today, 11 May | File before the day ends — late fee is ₹50/day from tomorrow under Section 47 |
| April 2023 GSTR-1 permanently locks after today | Check historical return status now — this is the absolute last filing window for that period |
| GSTR-3B Table 3 is auto-populated and hard-locked from GSTR-1 | Correct errors in GSTR-1A before filing GSTR-3B on 20 May |
| Late GSTR-1 blocks the buyer ITC chain | Your B2B buyers cannot claim April ITC in GSTR-2B until your GSTR-1 is filed today |
But here is the other side…
The 3-year lock under Section 37 prevents filing the return on the portal — it does not automatically extinguish a taxpayer’s right to claim that a supply was made. Where a business has original invoices, e-way bills and payment evidence showing genuine April 2023 transactions, the GST Appellate Tribunal has in some cases considered ITC disputes on merit, separate from the portal filing record. This matters if your buyers have already raised a formal ITC dispute on April 2023 supplies — a professional review is necessary before concluding all remedies are permanently closed.
You are already doing more than you know
Compliance in India is not designed to trap honest businesses — it is designed to create a paper trail that matches actual commerce. If you file GSTR-1 every month and keep your invoices, you are doing the fundamentals right. Today is about making sure one old gap does not become permanent before anyone noticed it was open.
WeConsult India works with businesses across Gurugram’s newer commercial clusters — including Sector 82, Sector 84 and the Southern Peripheral Road corridor — where growing teams and frequent accountant transitions often leave historical GST gaps undetected until deadlines like today surface them. If your company has any unfiled GSTR-1 returns from FY 2022-23 or FY 2023-24, today may be your last window for the earliest months.
Stay compliant. Stay protected. — WeConsult India