Key takeaways from the GST notifications of 31 March 2023 — amnesty for GSTR-4, GSTR-9, GSTR-10, revocation windows and what still applies in 2026.
The GST notifications issued by CBIC on 31 March 2023 marked a turning point for compliance, amnesty and registration revocation. Three years later, in FY 2026-27, many of those provisions continue to influence how taxpayers approach late returns, cancelled registrations and dormant GSTINs. This refreshed 2026 guide explains the key takeaways, what survives today, and how the Union Budget 2026 has built on that foundation.
Background and Why These Notifications Still Matter
On 31 March 2023, CBIC issued a cluster of notifications — primarily Notifications 02 to 08 of 2023 — that introduced amnesty schemes for non-filers of GSTR-4, GSTR-9, GSTR-10 and for revocation of cancelled registrations. They also extended the time limit for issuing assessment orders under Section 62 for non-filers. These measures cleaned up years of pending defaults and shaped the compliance posture that the CBIC continues to follow in 2026.
Key Takeaways from the 31 March 2023 Notifications
- Amnesty for non-filers of GSTR-4 (composition annual return) with reduced late fee
- Late fee rationalisation for GSTR-9 annual return for small taxpayers
- Amnesty for GSTR-10 (final return) on cancellation with capped late fee
- Window to apply for revocation of cancelled GST registration
- Extension of time limit under Section 62 to deem assessment orders withdrawn
- Aadhaar authentication and biometric checks tightened for new registrations
Impact on Composition Dealers and Small Taxpayers
Composition dealers who had missed GSTR-4 filings for multiple years could regularise their compliance at a capped late fee, often as low as ₹500 per return where no tax was payable. Similarly, taxpayers below the prescribed turnover threshold could file pending GSTR-9 returns at a reduced late fee. The intent was to bring lakhs of small taxpayers back into the active compliance net rather than leave them stranded with unaffordable penalties.
Revocation of Cancelled GST Registrations
Many genuine businesses had lost their GST registrations because of inability to file returns during the pandemic and post-pandemic years. The 31 March 2023 notification opened a special revocation window subject to filing all pending returns with applicable tax, interest and late fee. This route has been periodically reopened by CBIC, including under Finance Act 2026, where the framework for revocation continues with stricter Aadhaar and physical verification checks under the new registration regime.
How the 2026 Landscape Builds on These Changes
In FY 2026-27, CBIC has carried forward the spirit of the 2023 amnesty by introducing a structured dispute settlement mechanism under Section 128A for past period demands, automated late fee waivers for nil filers, and biometric Aadhaar authentication across high-risk states. The registration threshold remains at ₹40 lakh for goods, ₹20 lakh for services and ₹10 lakh in special category states, but the verification and ongoing monitoring on each GSTIN has tightened materially.
Action Points for Businesses in 2026
- Audit your GSTIN history for any cancelled or suspended registrations
- File pending GSTR-4, GSTR-9 and GSTR-10 to close legacy exposure
- Reconcile GSTR-2B input credits with books before September 2026 cut-off
- Complete Aadhaar authentication for all promoters and authorised signatories
- Use the Section 128A scheme to settle eligible pre-2024 disputes
How to Compute the Late Fee Today
If you are using the legacy amnesty calculations from 2023 directly, you risk under or over-paying. CBIC has periodically reset the maximum late fee under Sections 47 and 47A, often capping it at ₹500 per return where no tax is payable and at slab-based amounts for taxpayers with turnover up to ₹5 crore and above. Always pull the current notification before computing late fee on GSTR-4, GSTR-9 or GSTR-10. The GST portal also auto-computes the applicable late fee at the time of filing, which can be cross-verified against your working.
Section 62 Best-Judgement Assessment Withdrawals
The 31 March 2023 package extended the window under Section 62 within which a non-filer could file the pending return and get the best-judgement assessment order automatically deemed withdrawn. This provision continues to be a critical safety net in 2026 for taxpayers who receive a deemed assessment order. As soon as a Section 62 order is received, file the pending GSTR-3B with applicable tax, interest and late fee within the prescribed window — typically 30 days — to avoid the order becoming final and recoverable.
Conclusion
The 31 March 2023 GST notifications were more than a one-time amnesty — they reset the compliance baseline that CBIC has continued to enforce through 2026. If your business still has unfiled returns, a cancelled GSTIN or an open pre-2024 demand, the prevailing schemes notified by CBIC give you a structured path to clean up. Do not wait for assessment proceedings; act while the windows remain open.
