Answer

GST

Three-year bar on filing old GSTR-9C

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  1. Facts

    From the July 2025 changes, returns cannot be filed after three years from their due date. GSTN said FY 2020-21 GSTR-9 and GSTR-9C were barred from 1 December 2025.

  2. Provisions and law

    • Sec 39(11), CGST Act 2017A return cannot be filed after three years from its due date, subject to conditions notified.
    • Sec 44(1), CGST Act 2017Every registered person (other than notified classes) files an annual return by 31 December after the year; a self-certified reconciliation statement is filed with it where turnover exceeds the notified limit.
  3. Analysis

    If the bar applies, the portal will not accept the form. Pending liabilities for that year remain and can still be paid through DRC-03, and the department can still issue notices within limitation. Keep the reconciliation ready to answer questions. File current and recent years on time.

  4. Conclusion

    1. Check which years are still open on the portal.
    2. File pending years before the bar.
    3. Pay any liability for barred years through DRC-03.
    4. Keep reconciliations for possible notices.

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