Last updated . Rates, thresholds and dates reflect notifications and instructions in force on this date.
GST is a monthly system, and errors add up
Every invoice you issue and every credit you claim is matched by the GST system against what your customers and suppliers report. A small mismatch in one month can turn into blocked credit, a held refund or a notice two or three years later, when the facts are much harder to prove.
For exporters the stakes are higher. You pay GST on your purchases but charge little or none on exports, so the refund is your working capital. A clean, well-documented claim is paid in weeks. A weak one can sit with the department for months.
Registration, returns, e-invoices and e-way bills filed correctly and on time, with your books, GSTR-1, GSTR-3B and GSTR-2B telling the same story.
Getting back the tax that is due to you: refunds on exports and inverted duty structures, and standing up to demands that should not have been raised.
Three principles behind our GST work
Reconcile before you file
Liability in GSTR-3B is now locked to what you report in GSTR-1, so we fix errors before filing rather than after.
Build the file for the officer
A refund or reply is only as strong as its documents. We prepare each one as if it will be examined in detail.
Never miss a reply date
Most avoidable demands come from notices that were not answered. A structured compliance calendar keeps reply dates in view.
What changed in GST in 2025-26
GST changed more in the last twelve months than in any year since it began. Rates were restructured, returns were locked down, refunds moved to a risk-based system and the Appellate Tribunal finally started hearing cases. Here is what matters for your business.
Two main slabs from 22 September 2025
Under Notification 9/2025-Central Tax (Rate), most goods and services moved to 5% or 18%, with a 40% rate for a short list of luxury and sin goods. The 12% and 28% slabs were removed. From 1 February 2026, compensation cess ended and tobacco products moved to 40%.
For you: if the rate on your output fell but your inputs did not, you may now have an inverted duty structure, and the credit that builds up may be refundable.
GSTR-3B locked, old returns time-barred
From the July 2025 tax period, the liability auto-filled in GSTR-3B from GSTR-1 cannot be edited. Corrections go through GSTR-1A before GSTR-3B is filed. The portal also now blocks returns filed more than three years after their due date.
For you: an error in GSTR-1 now flows straight into your tax payment. Review sales data before you file, and clear any pending old returns now.
Risk-based 90% provisional refunds
Rule 91(2) was amended by Notification 13/2025-Central Tax, and CBIC Instruction 6/2025-GST applies it to refund applications filed from 1 October 2025. Claims the system rates as low-risk get 90% sanctioned provisionally, for exports and, as an interim measure, inverted duty claims.
For you: the Finance Act, 2026 amends Section 54(6) to put inverted duty provisional refunds into the law. As of our last check, its start date was still to be notified.
The Tribunal is hearing cases, including in Mumbai
The Principal Bench began hearings on 16 February 2026 and the Mumbai Bench from 27 July 2026. The special window for older appeals closed on 31 July 2026. New appeals follow the normal three-month limit with a 10% pre-deposit.
For you: an adverse first appeal order can now be taken further without years of waiting. Watch the three-month clock from the date of the order.
Our GST services
GST Registration & Return Filing
Sections 22, 24, 37, 39 and 44, CGST Act, 2017 · Rules 8 to 26 and 59 to 80, CGST Rules, 2017
We assist with registration and then with keeping the monthly cycle clean: sales reported, credit reconciled, tax paid and the annual return filed, with your books matching what the portal shows.
- New registration with Aadhaar authentication, including the three-working-day route for low-risk applicants under Rule 9A
- Amendments, additional places of business, cancellation and revocation
- GSTR-1 or IFF, GSTR-1A corrections and GSTR-3B, monthly or under the quarterly QRMP scheme
- Monthly Invoice Management System (IMS) review and GSTR-2B reconciliation with your purchase register
- Vendor-wise input tax credit reconciliation, with follow-up on suppliers who have not uploaded invoices or filed returns, since Section 16(2)(aa) allows credit only on invoices the supplier has reported
- Annual return in GSTR-9 and the self-certified reconciliation statement in GSTR-9C
- E-invoicing and e-way bill set-up and checks for businesses above the thresholds
Expert note: since the July 2025 tax period, the liability in GSTR-3B comes locked from GSTR-1. If an invoice was wrongly reported, the only same-month fix is GSTR-1A, filed before GSTR-3B. Once GSTR-3B is filed, the wrong tax has been paid, so GSTR-1 data is worth reviewing before it goes in.
GST Advisory & Impact Analysis
Sections 9, 14, 15, 16 and 17, CGST Act, 2017 · IGST Act, 2017 · Notification 9/2025-Central Tax (Rate)
Practical opinions on how GST applies to your products, contracts and supply chain, before a transaction rather than after a notice. Since GST 2.0, much of this work has been about checking rates and their effect on pricing and credit.
- HSN and SAC-wise mapping of your products and services to the GST 2.0 rates
- Classification, valuation and place of supply opinions, including for exports of services
- Input tax credit eligibility, blocked credits under Section 17(5) and reversals
- Reverse charge, Input Service Distributor and cross-charge reviews for multi-state businesses
- GST structuring of contracts, discounts and pricing, and inverted duty impact studies
- Support with advance ruling applications where the position is genuinely unclear
- GST health check or compliance review covering registration details, books-to-returns reconciliation, credit eligibility, reverse charge, e-invoice and e-way bill compliance and open notices, with a prioritised list of fixes
Expert note: when a rate changes, Section 14 decides which rate applies by looking at three events: the invoice, the payment and the supply. If two of the three happened before the change, the old rate applies. Advances received and bills raised around 22 September 2025 are worth checking against this rule.
Export Refunds
Section 16, IGST Act, 2017 · Sections 54 and 56, CGST Act, 2017 · Rules 89 to 96A, CGST Rules, 2017
GST refunds for exporters are where our practice has a proven track record. Exports are zero-rated, which means you should not carry the GST paid on your inputs. There are two ways to get it back, and choosing the right one, then filing it cleanly, decides how fast the money comes in.
File a Letter of Undertaking in RFD-11 for the financial year and export without paying IGST. The credit that builds up on inputs and input services is claimed in RFD-01, using the Rule 89(4) formula. Capital goods credit is excluded.
Charge IGST on the export invoice and pay it from your credit. For goods, the shipping bill is treated as the refund claim once the export manifest and GSTR-3B are filed, and Customs pays the refund after matching it with Table 6A of GSTR-1.
- LUT filing in RFD-11 each year, before the first export of the new financial year
- Refund of unutilised credit on exports of goods and services under LUT, filed in RFD-01 with the Rule 89(4) working
- IGST refunds on exported goods, including clearing ICEGATE errors such as invoice mismatches between the shipping bill and GSTR-1
- Inverted duty structure refunds under Rule 89(5), where tax on inputs is higher than on outputs
- Refunds for supplies to SEZ units and developers, and other zero-rated supplies
- Supplies to merchant exporters at the concessional 0.1% rate (0.05% CGST plus 0.05% SGST within the State) under Notifications 40/2017-Central Tax (Rate) and 41/2017-Integrated Tax (Rate), with the RCMC, purchase order and proof of export within 90 days that the concession depends on
- Replies to deficiency memos (RFD-03), follow-up on provisional (RFD-04) and final (RFD-06) orders, and claims for interest on delayed refunds
Timelines the department must follow. The claim must be filed within two years of the relevant date. The officer has 15 days to acknowledge it in RFD-02 or raise a deficiency memo in RFD-03. For zero-rated supplies, 90% can be released provisionally within 7 days of acknowledgement, and since 1 October 2025 that decision is driven by the system's risk rating. The final order is due within 60 days of the application. After that, interest at 6% a year runs in your favour.
Why deficiency memos are issued most often: statements and invoice lists missing or not matching GSTR-1, credit claimed that does not appear in GSTR-2B, bank realisation or foreign inward remittance proof not uploaded for service exports, the wrong period selected, or the refund working not tying back to the returns. Each of these is avoidable with a careful check before filing.
Expert note: a deficiency memo is not a rejection, but it does mean filing a fresh RFD-01. The time between your original filing and the memo is excluded from the two-year limit, so a memo near the deadline does not kill the claim. Not filing the corrected claim does. Separately, the Finance Act, 2026 omitted Section 13(8)(b) of the IGST Act, so intermediary services to overseas clients now follow the general place of supply rule and can qualify as exports. Agents and sourcing firms should revisit their position.
Departmental Notices & Representation
Sections 61, 73, 74, 74A, 107 and 112, CGST Act, 2017 · Rule 142, CGST Rules, 2017
From a scrutiny letter to a show cause notice to an appeal, we prepare the facts, the reconciliations and the legal position, and represent you before the officer. The aim is to close the matter at the earliest stage it can be closed.
- Replies to scrutiny notices in ASMT-10 and to mismatch and intimation notices on the portal
- Replies to pre-notice intimations (DRC-01A) and show cause notices (DRC-01), filed in DRC-06, with personal hearings
- Notices under Sections 73 and 74 for FY 2023-24 and earlier, and under the new Section 74A for FY 2024-25 onwards
- Advice on voluntary payment through DRC-03 where the demand is correct, to limit interest and penalty
- First appeals in APL-01 before the Appellate Authority, with the 10% pre-deposit
- Appeals to the GST Appellate Tribunal in APL-05, including its Mumbai Bench
Expert note: Section 74A uses one time limit for all cases: a notice within 42 months of the annual return due date and an order within 12 months of the notice. In a case without fraud, paying the tax and interest within 60 days of the notice means no penalty at all. For older years, FY 2023-24 is the last year under Section 73, where the order must come within three years of the annual return due date of 31 December 2024.
Other indirect tax work
What applies to your business
The main GST thresholds and requirements in force in 2026-27. Aggregate turnover is counted on an all-India basis for your PAN.
| Who | Requirement | When it applies | Law |
|---|---|---|---|
| Suppliers of goods only | Registration | Aggregate turnover above ₹40 lakh, including Maharashtra. Lower limits apply in some special category states | s.22, Notif. 10/2019-CT |
| Service providers | Registration | Aggregate turnover above ₹20 lakh (₹10 lakh in some special category states) | s.22, CGST Act |
| Inter-State goods suppliers, including exporters; e-commerce sellers | Registration | Whatever the turnover, subject to limited exemptions | s.24, CGST Act |
| Turnover up to ₹5 crore | QRMP option | Quarterly GSTR-1 and GSTR-3B, with tax paid monthly | Rule 61A |
| Turnover above ₹2 crore | GSTR-9 | Annual return mandatory. Up to ₹2 crore it is optional from FY 2024-25 | s.44, Notif. 15/2025-CT |
| Turnover above ₹5 crore | GSTR-9C | Self-certified reconciliation of books with the annual return | Rule 80(3) |
| Turnover above ₹5 crore | E-invoicing | B2B invoices, exports and credit or debit notes to be reported on the IRP | Rule 48(4) |
| Turnover ₹10 crore and above | 30-day e-invoice rule | Invoices and notes must be reported on the IRP within 30 days of their date, or they are rejected | GSTN advisory, from 1 Apr 2025 |
| Movement of goods | E-way bill | Consignment value above ₹50,000, generated within 180 days of the document date | Rule 138 |
| Exporters and SEZ suppliers not paying IGST | LUT | Filed in RFD-11 for each financial year before exporting | Rule 96A |
This is a summary for general guidance. Exact applicability depends on your turnover, the nature of your supplies and the notifications in force. Share your last GST returns and we will confirm what applies.
Key GST dates for the coming months
Statutory due dates for regular taxpayers in Maharashtra. The government sometimes extends dates, but only an official notification counts, so plan for the dates below.
-
11 Oct 2026
GSTR-1 for September 2026, for monthly filers.
-
13 Oct 2026
GSTR-1 for the July to September 2026 quarter, for QRMP filers.
-
14th of each month
GSTR-2B is generated from IMS. Act on supplier invoices before this date if you want them rejected or kept pending.
-
20 Oct 2026
GSTR-3B for September 2026, for monthly filers.
-
22 Oct 2026
GSTR-3B for the July to September 2026 quarter, for QRMP filers in Maharashtra.
-
30 Nov 2026
Last date to claim missed input tax credit of FY 2025-26 and to correct FY 2025-26 details in GSTR-1, unless the annual return is filed earlier.
-
31 Dec 2026
GSTR-9 and GSTR-9C for FY 2025-26.
-
Before 1 Apr 2027
LUT in RFD-11 for FY 2027-28, so that exports from 1 April can go out without IGST.
Who we help
GST issues differ by business. Exporters care most about refund speed and realisation records. Clearing and forwarding agents deal with place of supply and reverse charge questions. Manufacturers face inverted duty and job work issues, and service companies deal with cross-border billing and credit on common costs.
How we work on your GST
A fixed monthly routine for compliance, and a documented, step-by-step file for every refund or notice.
GST health check
We review your registration, recent returns, credit position and open notices, and list what needs fixing first.
Reconcile every month
Sales register against GSTR-1 and e-invoices, purchases against IMS and GSTR-2B, before anything is filed.
File on time
GSTR-1, GSTR-1A where needed and GSTR-3B filed by the due date, with a summary of tax paid and credit carried.
Build the refund file
Refund working, invoice statements, shipping bills and realisation proof tied to your returns before RFD-01 is filed.
Track and follow up
We watch for RFD-02, RFD-03, RFD-04 and RFD-06, reply to queries quickly and follow up with the officer.
Represent on notices
Written replies, personal hearings and appeals, with the reconciliations that make your case easy to accept.
Reconciliation, not re-typing
Good reconciliation starts from your accounting data and the portal's own downloads, so that GSTR-1, e-invoices, GSTR-2B and your books are matched line by line. Differences are explained or fixed each month, instead of piling up for the annual return or the next notice.
Common GST mistakes that cost money
These are among the most common issues for exporters and growing businesses. Each one is simple to prevent and slow to undo.
Shipping bill and GSTR-1 do not match
A different invoice number or value in the shipping bill and in Table 6A of GSTR-1 stops the IGST refund at Customs. A shipping bill cannot be changed after the export manifest is filed.
IGST in GSTR-3B short of GSTR-1
If the IGST paid in GSTR-3B is less than the IGST shown on export invoices in GSTR-1, the export data is not sent to Customs at all.
LUT not renewed
An LUT covers one financial year. Exporting in April without a fresh LUT means those exports should have carried IGST.
Refund based on credit not in GSTR-2B
Credit claimed in a refund that your suppliers have not reported leads to a deficiency memo or a reduced refund.
Export proceeds not realised on time
If payment is not received within the period allowed under FEMA, a refund already paid can be recovered, and LUT exports can become taxable.
Notices left unanswered
A scrutiny notice or intimation that is ignored usually becomes a demand order, and the three-month appeal window starts from that order.
Documents to keep ready
For monthly returns and, especially, for refund claims. Having these organised usually decides whether a refund is clean or queried.
- GST registration certificate and portal access details for your authorised signatory
- Sales and purchase registers with invoice-wise GST details
- Filed GSTR-1, GSTR-3B and the GSTR-2B for each month of the claim
- LUT acknowledgement in RFD-11 for the relevant financial year
- Export invoices, shipping bills and export manifest details for goods
- Bank realisation certificates, e-BRCs or foreign inward remittance certificates for service exports
- Export contracts or agreements with overseas clients for services
- Purchase invoices supporting the credit claimed in the refund period
- Previous refund orders, deficiency memos and replies
- All GST notices received, with replies filed and hearing records
Why clients choose us for GST
- Proven in export refunds. We have a proven track record in GST refunds for exporters.
- Founder-led. Direct founder involvement and accessibility on every engagement, so you are never passed around.
- An experienced team. CA Sejal Patel is supported by CA Bhoomi, Audit and Compliance Lead, and a team of 10+ experienced professionals working under direct founder supervision.
- Import and export experience. Our track record also covers import-side internal control reviews and certification work.
- Deadlines on track. Structured monthly compliance calendars and disciplined documentation processes keep returns, refunds and replies on schedule.
- Clear, practical advice. A transparent and ethical practice, with clear communication and business-oriented advice on your GST positions.
Frequently asked questions
Do I need GST registration if my turnover is below the threshold?
Usually not. The general limits are ₹40 lakh for businesses supplying only goods and ₹20 lakh for services, with lower limits in some special category states. But some businesses must register whatever their turnover, including anyone making inter-State supplies of goods, which covers exporters of goods, sellers through e-commerce operators and casual taxable persons.
What is the difference between CGST, SGST and IGST?
They are one tax, split by where the supply takes place. On a sale within a State you charge CGST, which goes to the Centre, and SGST, which goes to the State, in equal halves. In Union Territories without a legislature, UTGST takes the place of SGST. On an inter-State sale, an import, an export or a supply to an SEZ, IGST applies alone at the full rate. Charging the wrong one is costly: under Section 77 of the CGST Act and Section 19 of the IGST Act, the correct tax must be paid again and the wrong payment claimed as a refund. Credit also follows a set order. IGST credit is used first, and CGST credit cannot pay SGST, or the other way round.
Should a small business choose the composition scheme?
It suits businesses that sell mostly to consumers within one State and have few taxable purchases. Manufacturers and traders with aggregate turnover up to ₹1.5 crore in the previous year (₹75 lakh in some special category states) pay a flat 1%, and restaurants not serving alcohol pay 5%. Service providers have a separate option under Section 10(2A), up to ₹50 lakh at 6%. The trade-offs are real: you issue a bill of supply instead of a tax invoice, cannot claim input tax credit and cannot make inter-State outward supplies. Since October 2023 goods can be sold through e-commerce platforms within the State, but services cannot. Makers of ice cream, pan masala and tobacco products are excluded. Tax is paid quarterly in CMP-08 and the annual return is GSTR-4, due by 30 June. GST 2.0 changed the rates on goods, not these composition limits or rates. If your customers are registered businesses that want credit, or you sell outside Maharashtra, the regular scheme is usually the better choice.
Should I export under LUT or pay IGST and claim a refund?
Under an LUT you export without paying IGST and claim a refund of the input tax credit that builds up, by filing RFD-01. If you pay IGST on export of goods, the shipping bill itself works as the refund application and Customs pays the refund once the data matches. Exporters with high credit build-up often prefer the IGST route for goods, while service exporters usually use the LUT. The right choice depends on your inputs, cash flow and how clean your data is, so we work it out with your figures.
How long does a GST refund take?
Within 15 days of filing RFD-01, the officer must either acknowledge the claim in RFD-02 or issue a deficiency memo in RFD-03. For zero-rated supplies, 90% can be sanctioned provisionally within 7 days of acknowledgement, and since 1 October 2025 this is done on the basis of the system's risk rating, including for inverted duty claims. The final order is due within 60 days of the application, failing which interest at 6% a year is payable.
What is the time limit for claiming a GST refund?
Two years from the relevant date under Section 54 of the CGST Act. For exports this is broadly the date of export of the goods, or for services the date of receipt of payment. If the officer issues a deficiency memo, the time between your original filing and the memo is excluded from the two years when you file the corrected claim.
Can I get a refund of GST paid on services and capital goods under an inverted duty structure?
No. Under Rule 89(5), an inverted duty refund covers only credit on input goods. The Supreme Court upheld this in the VKC Footsteps case in 2021. For exports under LUT the position is better: credit on both inputs and input services counts towards the refund, though capital goods are excluded.
I have received a GST show cause notice. Should I pay or contest?
It depends on the merits, and on the year involved. For FY 2024-25 onwards, notices are issued under Section 74A. In a case without fraud, paying the tax and interest within 60 days of the notice means no penalty is payable. Where the demand is wrong, a well-documented reply in DRC-06 and, if needed, an appeal within three months of the order is the better course. Never let the reply date pass without responding.
Is the GST Appellate Tribunal working now?
Yes. The Principal Bench in New Delhi began hearings on 16 February 2026 and the Mumbai Bench began hearing cases from 27 July 2026. The special window for older appeals closed on 31 July 2026. New appeals must be filed within three months of the first appellate order, with a further pre-deposit of 10% of the tax in dispute.
Can I still file an old GST return that I missed?
Only if it is within three years of its due date. Since the July 2025 tax period, the GST portal blocks filing of GSTR-1, GSTR-3B, GSTR-9 and other returns once three years from the due date have passed. If you have gaps, file them now before they become time-barred.
Can a GST return be revised after filing?
No. GSTR-1 and GSTR-3B cannot be revised once filed. An error in GSTR-1 can be corrected in GSTR-1A for the same period, before GSTR-3B is filed, or by amendment in a later GSTR-1. Since the July 2025 tax period, the liability in GSTR-3B comes locked from GSTR-1 and GSTR-1A, so any short or excess tax is adjusted in a later month's return, with interest where tax was paid late. Corrections and missed credit for a financial year must be made by 30 November of the following year, or the date the annual return is filed if earlier. And a return not filed within three years of its due date can no longer be filed at all.
Is the Invoice Management System mandatory?
Using IMS is optional, but it affects you either way. Invoices you do not act on are treated as accepted and flow into GSTR-2B, which is generated on the 14th of each month and drives the credit in GSTR-3B. Reviewing IMS each month is the simplest way to avoid claiming credit you cannot support later.
This page is general information for businesses and is not professional advice for any specific situation. GST rates, thresholds, forms and due dates change through notifications, circulars and portal advisories. Please consult us before acting on it.