GST
Old year GSTR-9 is now time barred
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Facts
Sec 44(2) bars filing an annual return after three years from its due date. The portal has applied this bar, and FY 2020-21 annual returns could not be filed from 1 December 2025.
Provisions and law
- Sec 44(2), CGST Act 2017Annual return cannot be filed after three years from its due date
- Sec 44, CGST Act 2017Every registered person, other than excluded categories, files an annual return for each financial year
Analysis
Being barred does not mean the matter is over. The department can still examine the year through scrutiny or demand under Sec 73, 74 or 74A within their own time limits. Late fee for non-filing may also be raised. Keep year-wise reconciliations for barred years, and pay any clear short tax through DRC-03 so it is on record. Take advice on exposure before a notice arrives.
Conclusion
- List all years where GSTR-9 was required but not filed
- Check which years are past the three-year bar
- File immediately any year that is still open
- For barred years, prepare a reconciliation and keep evidence ready for notices
A barred return is still a compliance gap for notices; do not ignore it.
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