Section 16(4) ITC Deadline

The single most unforgiving deadline in GST

Unlike a return filing deadline, which can technically still be met late (subject to the late fee, interest, and now the three-year cap), Section 16(4)'s ITC deadline doesn't offer even that option — credit not claimed by the cutoff simply lapses, permanently, with no notified mechanism to recover it afterward. For FY 2025-26 invoices, that cutoff is 30 November 2026, or the actual date the FY 2025-26 GSTR-9 is filed, whichever occurs first.

This creates a genuine year-end scramble for firms reconciling vendor invoices against their own purchase records — any invoice where the vendor either didn't upload it in their GSTR-1, or where the recipient simply missed claiming the credit in a monthly/quarterly return before the cutoff, represents a permanently lost credit, not a delayed one.

Building a reconciliation habit before the cutoff, not after

Because the loss is permanent and there's no late-filing equivalent to fall back on, the practical response is a disciplined GSTR-2B reconciliation habit running throughout the year, not a single scramble in the final weeks before 30 November. Comparing claimed ITC against GSTR-2B monthly or quarterly — rather than waiting for an annual push — surfaces vendor-side gaps (an invoice simply never uploaded) early enough to chase the vendor for a correction while there's still time, instead of discovering the gap only when it's already unrecoverable.