GSTR-1 Is Due Today — And One Old Return Is Closing Forever
Published on:
Category: TAX
Author: CS Nawal Kishore Verma
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🔴 TWO DEADLINES TODAY |
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DEADLINE ALERT: GSTR-1 for April 2026 is due today, May 11. And April 2023 GSTR-1 locks permanently after today under Section 37, CGST Act. Two deadlines. Same date. Most businesses know only one. |
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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 sent a WhatsApp: Sir, GSTR-1 today. He clicked through to the Returns Dashboard and started preparing 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.
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[EXPERIENCE SIGNAL] The kind of compliance gap that costs a business its entire ITC trail for a month does not happen because anyone was dishonest. It happens because April 2023 was a month of team transitions — and nobody had the presence of mind to look backward when they were busy looking forward. |
That return has been sitting there for three years. Today is the last day anyone can touch it. After today, the GST portal will block it — permanently, with no override, no appeal, and no late-fee payment that can reopen it.
What Most Businesses Are Missing Right Now
Most business owners know GSTR-1 is due on the 11th of every month. 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 May 11, 2023. Three years from that date is exactly today. After today, the portal will not accept the April 2023 return — not for any reason, and not for any amount.
The wrong reaction is to treat today as a single-task day. The 3-year lock has been running silently since 2022. Month by month, old returns have been closing. March 2023 closed on April 11, 2026. April 2023 closes today. May 2023 will close on June 11, 2026.
Think of your unfiled old returns as a time-locked vault inside a bank. You know you need to make a deposit today — that is the April 2026 filing. But there is a second compartment from 2023, set to seal shut at a fixed time. Once the timer runs out, not even the bank manager can open it. The bank does not destroy the records. It just makes them permanently inaccessible.
What the Law Actually Says
Under Section 37 of the CGST Act, 2017 — as amended by the Finance Act 2022 — a registered taxpayer cannot file a GSTR-1 return 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 return is like a shipping manifest sent to a freight exchange. Until your manifest arrives, your buyers cannot confirm their cargo. Once you file, their GSTR-2B is updated on the 14th — and they can claim Input Tax Credit. If you do not file, they cannot claim. And if the portal locks your old return, no invoice or payment record will restore the ITC chain.
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Regulatory Event |
What It Means for Your Business |
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Section 37 CGST Act — 3-year portal lock (Finance Act 2022) |
April 2023 GSTR-1 (due May 11, 2023) cannot be filed after today — portal permanently blocks access |
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GSTR-1 for April 2026 due today |
Monthly filers with turnover above ₹5 crore must file today; late fee ₹50/day from tomorrow under Section 47 CGST Act [1] |
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Late GSTR-1 blocks buyer ITC |
Your buyers cannot claim April 2026 ITC in GSTR-2B (generated May 14) until you file your GSTR-1 today |
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GSTR-3B now hard-locked from GSTR-1 |
From July 2025, Table 3 in GSTR-3B is auto-populated from GSTR-1 and cannot be manually overridden — accuracy today is non-negotiable [2] |
What Happened to Vikram — and What Priya Did Differently
Both Vikram and Priya own mid-sized manufacturing firms in Gurugram, both with turnovers above ₹5 crore. Both had a difficult April 2023 — a finance team changeover, vendor disputes, and a busy quarter-close. In both companies, the April 2023 GSTR-1 slipped. Nobody noticed at the time.
This morning, Priya's team pulled a historical return status report before starting today's filing. The April 2023 gap came up. They filed it immediately — paid the applicable late fee of ₹50 per day for the period of default [1]. That is not a small amount. But it is manageable. And her buyers' ITC trail for that month stayed intact.
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Vikram filed April 2026 GSTR-1, closed the laptop, and moved on. By evening, the April 2023 window will have closed. The ₹14 lakh worth of B2B invoices from that month — supplies made to four customers — will never appear in any GSTR-2B. If any of those customers raise an ITC dispute today, Vikram has no portal-level path to correct it. |
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 — Five Steps
1. Check April 2026 GSTR-1 status immediately — Log in to gst.gov.in, go to Returns > Returns Dashboard, select April 2026, and confirm GSTR-1 status. If not filed, begin immediately. Monthly filers have until today. Every hour matters — the portal slows under peak traffic near deadlines.
2. Pull a historical return status check before closing the tab — On the same portal, go to Returns > View Filed Returns. Check every month from April 2023 onward. Any Not Filed status from April 2023 is in the final window today. May 2023, June 2023, and beyond have their own closing dates — but April closes tonight.
3. Contact WeConsult India if any historical return shows unfiled — Do not attempt to backfile without first reviewing the ITC implications, applicable late fees, and correct filing sequence. WeConsult India can assess your position and guide you through the process before the window closes. A 30-minute call today could prevent a three-year liability becoming permanent.
4. Brief your accountant on the GSTR-3B hard-lock — From the July 2025 tax period onward, GSTR-3B Table 3 is auto-populated from your GSTR-1 data and cannot be manually overridden [2]. Any error in today's GSTR-1 must be corrected through GSTR-1A before you file GSTR-3B on May 20. Make sure your team knows this workflow before May 20 arrives.
5. Set a reminder for May 20 today — GSTR-3B for April 2026 is due on May 20, 2026. Mark it now. The data you submit in GSTR-1 today directly determines what auto-populates in GSTR-3B 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
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Key Compliance Point |
What You Must Do |
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GSTR-1 for April 2026 is due today, May 11 |
File before the day ends — late fee is ₹50/day from tomorrow under Section 47, CGST Act |
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April 2023 GSTR-1 permanently locks after today |
Check historical return status now — this is the absolute last filing window for that period |
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GSTR-3B Table 3 is auto-populated and hard-locked from GSTR-1 |
Correct errors in GSTR-1A before filing GSTR-3B on May 20, 2026 |
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Late GSTR-1 blocks 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 of the CGST Act prevents filing the return on the portal — it does not automatically extinguish a taxpayer's right to claim that a supply was made. In cases where a business has original invoices, e-way bills, and payment evidence showing genuine transactions for April 2023, 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 that 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 are filing GSTR-1 every month and keeping 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.
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WeConsult India works with businesses across Gurugram's newer commercial clusters — including companies in Sector 82, Sector 84, and the Southern Peripheral Road corridor — where growing teams and frequent accountant transitions often leave historical GST filing 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
This blog is for informational purposes only and does not constitute legal or professional advice. Please consult a qualified Company Secretary or Chartered Accountant before acting on any compliance matter.
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TAX
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The Story : The Income Tax Act, 1961 was repealed on April 1, 2026. Replaced by the Income Tax Act, 2025. Tax rates unchanged. Section numbers changed. The income tax portal now has two tabs. Wrong tab in July 2026 = defective return. Sunita runs a trading company in Gurugram. When her CA WhatsApp-forwarded an article in April saying the Income Tax Act 2025 had replaced the 1961 Act, she read the headline, assumed it meant higher taxes, and scrolled past. It did not mean higher taxes. Her tax rates are exactly the same. Her deductions are the same. Her July 2026 ITR will calculate identically to last year. But when she opens the income tax portal in July 2026, she will see something she has never seen before: two separate tabs. Tab 1: Income Tax Act 1961. Tab 2: Income Tax Act 2025. If she — or her CA — clicks the wrong tab, her return will be treated as defective. The new Act is not a tax hike. 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Use Tab 1 on the income tax portal. The new Act applies only from Tax Year 2026-27 — your first return under the new Act is in July 2027. Sunita vs Aman — The Same July 2026 Filing, Two Very Different Results Aman's CA read about the transition in March. When Aman's July return was prepared: Tab 1 on the portal — Income Tax Act 1961. All section references correct. TDS certificates for FY 2025-26 referencing old numbers — which is correct for pre-April 2026 transactions. Return processed cleanly. Sunita's accountant defaulted to Tab 2. The portal flagged a mismatch: FY 2025-26 income in a Tax Year 2026-27 form structure. Return returned as defective under Section 139(9) with a 15-day rectification window. Defect rectified after consulting WeConsult India — resubmitted under Tab 1. No penalty. But one additional week of anxiety, additional professional fees, and a refund delayed by six weeks. The difference is not tax knowledge. It is transition knowledge — knowing which year is governed by which law. How to Actually Start — 5 Things Every Business Owner Must Do Before July 2026 1. Step 1 — Confirm which portal tab your CA is using for the July 2026 filing — The income tax portal now has two tabs. For FY 2025-26 income (AY 2026-27) — what most businesses will file in July 2026 — your CA must use Tab 1 (Income Tax Act 1961). If your accountant or software has defaulted to Tab 2, the return will be prepared against the wrong legislative framework. Ask this question explicitly before filing begins. 2. Step 2 — Verify that your TDS certificates for FY 2025-26 reference the correct old section numbers — TDS deducted from payments made to you during FY 2025-26 should reference old 1961 Act section numbers (194C, 194J, 192, etc.) because the transactions occurred before April 1, 2026. If a deductor has already updated their software and issued certificates with new section numbers for pre-April 2026 transactions, those certificates may be defective. Raise this with your CA during the Form 26AS reconciliation. 3. Step 3 — Update accounting and payroll software before the first Tax Year 2026-27 TDS filing — From April 1, 2026, all new TDS deductions must be processed under the Income Tax Act, 2025. Salary TDS = Section 392. All non-salary TDS = Section 393. TCS = Section 394. If your payroll or accounting software has not been updated, your Q1 Tax Year 2026-27 TDS challans will cite incorrect sections. The CBDT has confirmed this will cause processing issues. Check your software update status this week. 4. Step 4 — Brief your bank about the new Form 121 for TDS exemption declarations — Form 15G and Form 15H are replaced by single Form 121 under the Income Tax Rules, 2026. If your bank is still issuing Form 15G or Form 15H for transactions after April 1, 2026, the forms are no longer valid. Raise this with your banker if you rely on TDS exemption declarations for business deposits. 5. Step 5 — If you have a pending updated return for FY 2020-21 it is now permanently closed — The window to file an updated return (ITR-U) for FY 2020-21 has permanently closed from April 1, 2026. If you have any pending ITR-U filings for FY 2021-22 or FY 2022-23, file them now — the penalty rates have gone up from April 1, 2026. Rates now range from 25% to 60% additional tax depending on delay. The Income Tax Act has a new name. The traps for filers are also new. Make sure your July 2026 filing accounts for both. Key Takeaways Key Compliance Point What You Must Do July 2026 ITR for FY 2025-26 is STILL under Income Tax Act, 1961 Confirm your CA is filing on Tab 1 (1961 Act) of the income tax portal — not Tab 2 (2025 Act) TDS section numbers changed for transactions after April 1, 2026 Update accounting and payroll software — salary TDS = Sec 392, all other TDS = Sec 393, TCS = Sec 394 Form 15G and Form 15H replaced by Form 121 from Tax Year 2026-27 Brief your bank — old forms no longer valid for transactions after April 1, 2026 Updated return window for FY 2020-21 permanently closed from April 1, 2026 If you have pending ITR-U for FY 2021-22 or FY 2022-23, file immediately — penalty rates have increased But Here Is the Other Side… But here is the other side: the Income Tax Act, 2025 is genuinely a simpler law for most taxpayers, not a more complicated one. The consolidation of 37+ TDS sections into three is a real compliance simplification for businesses dealing with multiple vendor payment types. The single Tax Year concept eliminates the confusion between Previous Year and Assessment Year that has confused first-time filers for decades. The extended 48-month window for updated returns gives taxpayers more time to correct past filings. And the plain-language drafting of the new Act was explicitly designed to be more readable — reducing the dependency on professionals for routine compliance questions over time. The transition disruption is real but temporary. The long-term direction is a simpler system. One Last Thing — The Law Changed. Your July Filing Has Not. The Income Tax Act, 2025 went live 32 days ago. But for the return you file in July 2026, nothing changes. Same income. Same deductions. Same portal login. Just — Tab 1. Not Tab 2. The confusion in the July 2026 filing season will not come from the tax calculations. It will come from accountants, software, and forms that have not been updated for the transition. The best protection is a simple conversation with your CA: which tab, which sections, which forms — for FY 2025-26 versus Tax Year 2026-27. WeConsult India assists businesses across Gurugram's Sector 82, Sector 84, and the Cyber Hub corridor with FY 2025-26 income tax return preparation, TDS compliance transition under ITA 2025, and ITR-U filings before penalty escalations take effect. Stay compliant. Stay protected. — WeConsult India This blog is for informational purposes only and does not constitute legal or professional advice. Please consult a qualified Company Secretary or Chartered Accountant before acting on any compliance matter.
TAX
Risk Management System (RMS) Under the Income Tax Act: Meaning, Notices, Triggers & Taxpayer FAQs
In the age of digital tax governance, the Income Tax Department of India relies heavily on data analytics to monitor compliance. One such powerful mechanism is the Risk Management System (RMS). This system plays a critical role in identifying income tax returns (ITRs) that may require verification, correction, or further review. Understanding RMS is essential for taxpayers, professionals, and businesses to avoid unnecessary notices, refund delays, or compliance issues. What Is the Risk Management System (RMS)? The Risk Management System (RMS) is an automated, technology-driven screening mechanism used by the Income Tax Department to analyze filed income tax returns. It applies predefined risk parameters and data-matching algorithms to detect potential inconsistencies, high-risk claims, or mismatches with third-party information. RMS works silently in the background and helps the department focus on returns that genuinely require attention, thereby improving efficiency and reducing manual scrutiny. Why Was RMS Introduced? The RMS framework was introduced to: Promote voluntary tax compliance Reduce manual and selective scrutiny Detect high-risk or abnormal tax positions Speed up refund processing Enhance transparency under the faceless assessment system This system ensures that compliant taxpayers are not unnecessarily disturbed while risky cases are reviewed systematically. Common Reasons Why an ITR Gets Flagged Under RMS An income tax return may be flagged under RMS due to one or more of the following reasons: Large or unusual refund claims High deductions under sections like 80C, 80D, HRA, or home-loan interest Mismatch between ITR, Form 16, Form 26AS, AIS, or TIS Non-reporting or under-reporting of income High-value financial transactions not aligned with declared income Sudden change in income pattern compared to previous years It is important to note that an RMS flag does not automatically mean wrongdoing. In many cases, it is a data-driven alert seeking clarification. How Does RMS Communication Reach the Taxpayer? If your return is flagged, you may receive: An intimation under Section 143(1) A request for clarification on the income tax portal A prompt to revise the return, if required These communications are usually sent via: Registered email ID Income Tax e-Filing portal dashboard Timely action is crucial to avoid escalation. What Should You Do After Receiving an RMS Intimation? Carefully review the intimation Compare figures with Form 16, 26AS, AIS, and TIS Identify whether there is: - A genuine mistake → file a revised return - No mistake → submit a confirmation or explanation Respond within the prescribed timeline Ignoring the communication may lead to delayed refunds or further notice Frequently Asked Questions (FAQs) Q1: Is RMS the same as scrutiny or assessment? A: No. RMS is a preliminary risk-screening tool. It does not automatically result in scrutiny or assessment. Only selected high-risk cases move to further stages. Q2: Does receiving an RMS intimation mean I will be penalized? A: Not at all. Most RMS intimations are clarificatory in nature. Penalties arise only if discrepancies remain unresolved or involve misreporting. Q3: Can salaried taxpayers also receive RMS notices? A: Yes. Salaried individuals can receive RMS flags due to mismatches in salary income, deductions, multiple Form 16s, or incorrect HRA claims. Q4: Will my income tax refund be stopped if RMS is triggered? A: Refunds may be temporarily withheld until clarification or correction is completed. Once resolved, refunds are usually processed smoothly. Q5: Is it mandatory to revise the return after RMS intimation? A: No. A revised return is required only if an error exists. If your return is accurate, you can simply confirm or respond with correct justification. Q6: How much time do I get to respond to RMS communication? A: Generally, taxpayers are given 30 days, but timelines may vary depending on the communication type. Always check the deadline mentioned in the notice. Q7: Can RMS trigger notices for previous years? A: RMS mainly applies to the current assessment cycle, but historical data is used for comparison and risk analysis. Q8: How can professionals help in RMS cases? A: RTax professionals help by: • Reviewing RMS triggers • Verifying data with tax records • Drafting proper responses • Filing revised returns where required • Preventing escalation into scrutiny How WeConsult India Can Help At WeConsult India, we assist individuals, professionals, startups, and businesses with: RMS notice analysis & response Income tax return revision Refund follow-ups Compliance risk review End-to-end income tax advisory Our expert-led approach ensures accurate responses, timely action, and peace of mind. Conclusion The Risk Management System under the Income Tax Act is designed to strengthen compliance, not to penalize honest taxpayers. Understanding how RMS works and responding promptly to any intimation is the key to smooth tax filing and faster refunds. Staying informed and seeking professional support when needed can help you avoid unnecessary tax stress and future complications.