ITC Time Limit Under Section 16(4): FY 2025-26 Deadline and Rules

Last verified: 22 October 2026, against the current CGST Act and CBIC guidance. GST provisions change by notification, so confirm the position for your facts before acting.

Before you rely on that date, four points matter:

1. The statutory time limit is not the same as the conditions for ITC eligibility. Meeting the deadline does not, by itself, make a claim valid.
2. Furnishing the relevant annual return earlier can bring the applicable cut-off forward from 30 November 2026.
3. Visibility in GSTR-2B alone does not guarantee entitlement to the credit.
4. Review your purchase records, the ITC already claimed, and any unresolved discrepancies before the applicable deadline.

 

What Is the ITC Deadline for FY 2025-26?

FY 2025-26 runs from 1 April 2025 to 31 March 2026. Under the ordinary Section 16(4) rule, eligible ITC on invoices and debit notes relating to that year must be taken in a GSTR-3B filed on or before 30 November 2026, unless the relevant annual return is furnished earlier and closes the window sooner.

Why is 30 November 2026 important?

The financial year ends on 31 March 2026. Section 16(4) then sets an outer date of 30 November following the end of that year, which is 30 November 2026. The timeline below shows the normal rule. It is not a substitute for checking your own filing circumstances.

What does “whichever is earlier” mean?

If a registered person furnishes the relevant annual return before 30 November 2026, the Section 16(4) time limit can end on that earlier date instead. For example, if the GSTR-9 for FY 2025-26 is filed on 15 October 2026, the window for taking FY 2025-26 ITC ordinarily closes on 15 October 2026, not 30 November.

Delaying an annual return should not be treated as a recommended way to extend ITC availability. Filing obligations and ITC time limits are separate matters and should be considered on their own terms.

Does the deadline apply to every ITC claim?

Section 16(4) deals only with the time limit for taking credit on invoices and debit notes. It does not remove the other conditions and restrictions that apply to ITC. A credit can be within time and still be ineligible if the substantive conditions are not met.

What Is Section 16(4) of the CGST Act?

Section 16(4) is the provision that fixes the last date for taking input tax credit. For a business closing its financial-year records, it sets the outer boundary of when eligible credit can still be reported.

In substance, the subsection provides that a registered person is not entitled to take ITC in respect of any invoice or debit note after the thirtieth day of November following the end of the financial year to which such invoice or debit note pertains, or the furnishing of the relevant annual return, whichever is earlier. This wording reflects the amendment made by the Finance Act, 2022, which moved the earlier September cut-off to 30 November.

• What it restricts: the date by which eligible ITC on an invoice or debit note can be taken in GSTR-3B.
• How the relevant year is identified: by the financial year to which the invoice or debit note pertains.
• The ordinary cut-off: 30 November following the end of that financial year.
• The effect of the annual return: furnishing it earlier can bring the cut-off forward.
• A separate check: the time limit should always be assessed apart from the substantive eligibility conditions.

Section 16(4) versus ITC eligibility

Section 16(4) is a time-bar. Whether the credit qualifies at all is governed by Section 16(2), which sets the core conditions, by the restrictions in Section 17 (including the blocked credits in Section 17(5)), and by the applicable documentation requirements. A claim must clear both the time limit and the substantive conditions. For the eligibility basics, see the ProfitBooks guide to input tax credit.

 

Which Invoices and Debit Notes Should You Review Before the Deadline?

A FY 2025-26 ITC review should look across every document that could affect the final credit position:

• Purchase invoices relating to FY 2025-26.
• Debit notes, with their relevant financial year determined correctly.
• Invoices recorded in your books but missing from supplier-reported information.
• Invoices appearing in GSTR-2B but not recorded in your purchase register.
• Potentially eligible credit that has been identified but not yet claimed.
• Amendments, credit notes, reversals and adjustments that change the final ITC position.

Does a debit note have a separate time limit?

Yes. Following the amendment to Section 16(4) by the Finance Act, 2020 (effective 1 January 2021), the relevant financial year for a debit note is determined by the date of the debit note itself, not the date of the original invoice. For example, a debit note dated April 2026 that relates to an original invoice from January 2026 pertains to FY 2026-27, so it carries its own deadline. Map each debit note separately rather than assuming it follows the original invoice year.

What if an invoice is identified late?

Discovering an invoice late does not extend the statutory deadline. The clock runs from the financial year to which the document pertains, not from the date you found it. Where a document surfaces late, verify the invoice date, the relevant financial year, the supporting documentation, the eligibility conditions, whether the credit was already claimed, and whether the time limit is still open.

What Conditions Must Be Met Before Claiming ITC?

Meeting the deadline is necessary, but it does not make a claim valid on its own. Section 16(2) sets the core conditions, and each must be satisfied independently.

Valid tax invoice or prescribed document

You must hold a valid tax invoice or another prescribed document for the supply, and the details on it should be checked. A missing or defective document undermines the claim regardless of the deadline.

Receipt of goods or services

The goods or services must have been received. Where goods are received in lots or instalments against a single invoice, the credit is ordinarily available only on receipt of the last lot or instalment, to the extent the legislation provides.

Supplier reporting and GSTR-2B

Supplier-reported information and GSTR-2B are central to the review, because the credit is linked to details furnished by the supplier. An invoice appearing in GSTR-2B does not, by itself, prove that every ITC condition is satisfied. Possession of the document, actual receipt of the supply, and the Section 17 restrictions still need separate confirmation. The ProfitBooks guide to GSTR-2B walks through the reconciliation in more detail.

Return-filing requirements

The recipient must have furnished the relevant return in which the credit is taken. ITC is claimed through a validly filed GSTR-3B, so the return-filing condition is part of a complete claim.

Blocked credits and reversals

Some credits are restricted or require reversal depending on the transaction. Section 17(5) blocks credit on specified items and circumstances, and Rule 37 requires reversal where the supplier is not paid within 180 days, with a reclaim allowed once payment is made. Apply these only where the tax treatment of the specific purchase is verified, rather than as a blanket rule.

 

GSTR-2B vs Purchase Register: What Should You Reconcile?

This is where most unclaimed ITC is found, and where most errors hide. Invoice-level reconciliation compares three data sets: your purchase register (what you recorded), GSTR-2B (what suppliers reported), and the ITC already claimed in your GSTR-3B returns. Differences should be investigated, not automatically classified as eligible or ineligible.

The Invoice Management System (IMS) on the GST portal adds a further step: pending, accepted or rejected records should be reviewed as part of reconciliation, but IMS status is not a substitute for the statutory eligibility test.

How should businesses prioritize unresolved differences?

Review first the discrepancies that may affect a time-limited claim, such as potentially eligible credit that is still unclaimed and invoices missing from GSTR-2B, while continuing to apply all eligibility conditions. A supplier correction is not guaranteed to be completed before the deadline, and not every discrepancy will be recoverable, so start early and keep an exception log.

 

How to Calculate Potentially Unclaimed ITC for FY 2025-26

A simple illustration shows how to size the amount that needs review:

Potentially unclaimed ITC = potentially eligible ITC identified, minus ITC already claimed, adjusted for applicable reversals, credit notes and other relevant corrections. In this example the ₹35,000 is a balance that requires review, not an automatic entitlement to claim.

For each item in that balance, verify whether the credit meets the eligibility conditions, whether it has already been claimed, whether a reversal or adjustment applies, whether the relevant time limit is still open, and whether the relevant annual return has been furnished. A software total or a GSTR-2B figure does not, on its own, establish a legally valid claim.

 

What Happens If You Miss the ITC Deadline?

ITC taken after the applicable Section 16(4) time limit is ordinarily not available, and the credit lapses for that financial year. An earlier annual-return date can bring that cut-off forward, and the appearance of an invoice in GSTR-2B does not override the statutory time limit. Even where a claim can no longer be taken, keeping the supporting records remains important for audit and assessment.

Do Sections 16(5) and 16(6) provide exceptions?

Sections 16(5) and 16(6) were inserted by the Finance (No. 2) Act, 2024, and clarified by CBIC Circular No. 237/31/2024-GST dated 15 October 2024. Section 16(5) provides retrospective relief for ITC relating to FY 2017-18 to FY 2020-21, where the credit was taken in a return filed up to 30 November 2021. Section 16(6) addresses cases where a registration was cancelled and the cancellation was later revoked. These are defined, period-specific provisions. They are not a general extension for ordinary FY 2025-26 claims.

Can a return correction restore time-barred ITC?

Correcting an accounting record or a return discrepancy is not the same as meeting the statutory time limit for taking ITC. Filing an amendment, fixing a document or submitting a later return does not, by itself, restore a claim that is otherwise time-barred. Where your circumstances involve cancellation of registration, litigation or another special situation, check the applicable statutory provisions and obtain professional advice.

 

ITC Deadline Checklist for Businesses

Work through this review well before the cut-off, not on the final day:

1. Download your FY 2025-26 purchase and invoice records.
2. Obtain the relevant GSTR-2B data for each return period.
3. Compare the purchase register against supplier-reported invoices.
4. Review ITC already claimed in GSTR-3B.
5. Identify potentially eligible unclaimed credit.
6. Investigate missing invoices, amendments and credit notes.
7. Review blocked credits under Section 17(5) and applicable Rule 37 reversals.
8. Confirm the financial year relevant to each invoice or debit note.
9. Check whether the relevant annual return has already been furnished.
10. Resolve outstanding issues and document the final review.
11. Take eligible ITC within the applicable statutory time limit.
12. Retain supporting documents and reconciliation records.

 

How Accounting Software Can Help With ITC Reconciliation

Organized accounting records make an ITC review far easier to complete on time. Well-maintained books help with recording purchase invoices, tracking tax amounts, identifying discrepancies, reviewing the ITC already claimed, maintaining an audit trail, and preparing reports for your finance team or tax professional. ProfitBooks helps small businesses keep purchase records organized and generate the reports useful for GST reconciliation. It supports the review and does not determine legal eligibility, guarantee compliance, or file returns on your behalf, so the statutory checks above still apply.

 

Frequently Asked Questions About the FY 2025-26 ITC Deadline

 

Conclusion: Review Your FY 2025-26 ITC Before the Applicable Cut-Off

The practical next steps are straightforward: review your purchase invoices and debit notes, reconcile the purchase register with GSTR-2B, check the ITC already claimed, investigate outstanding discrepancies, verify eligibility and any reversals, and confirm the date on which the relevant annual return was furnished. Then take eligible credit within the applicable time limit.

The ordinary Section 16(4) time limit is 30 November following the end of the relevant financial year, or the date of furnishing the relevant annual return, whichever is earlier, subject to any specifically applicable statutory provision. For FY 2025-26, that outer date is 30 November 2026. Complete the review in good time rather than leaving it to the final day.