GST notifications on 31st March,2023

GST Notifications on 31st March, 2023: The Complete Compliance Guide for 2026

On 31 March 2023, CBIC issued a coordinated cluster of Central Tax notifications — principally Nos. 02/2023-CT through 08/2023-CT — that granted amnesty to hundreds of thousands of non-filers of GSTR-4, GSTR-9 and GSTR-10, reopened a window to revoke cancelled GST registrations, and recalibrated the Section 62 best-judgement assessment timeline. Three years on, in FY 2026-27, these provisions remain the reference point for every late-fee computation, registration revival decision and pre-assessment settlement you are likely to encounter in practice.

What CBIC Issued on 31 March 2023 — The Full Notification Stack

The 31 March 2023 package was not a single announcement but a coordinated legislative act spread across several notifications issued under the Central Goods and Services Tax Act, 2017. Each had a corresponding State Tax or Union Territory Tax notification mirroring the rates, so every figure you see below doubles when you combine CGST and SGST/UTGST.

Additional notifications in the same tranche addressed Aadhaar authentication, Section 62 assessment timelines, and rule amendments to Form GST REG-21. Together, they represented one of the most consequential one-day compliance resets since the GST rollout in July 2017.

Why the timing mattered: By March 2023, the GSTN database held millions of non-filed returns, tens of thousands of cancelled registrations, and a growing volume of Section 62 deemed assessments. A legislative intervention on the last day of the financial year allowed CBIC to reset the compliance baseline cleanly before FY 2023-24 opened — and it set the template for the compliance philosophy CBIC has continued to apply through 2026.

GSTR-4 Amnesty for Composition Dealers (Notification 02/2023-CT)

Who qualified

Composition scheme dealers — businesses registered under Section 10 of the CGST Act who pay tax at a flat rate on turnover and file GSTR-4 as their annual return — were the primary beneficiaries. Any composition dealer who had failed to file GSTR-4 for one or more years between FY 2017-18 and FY 2021-22 qualified for the reduced late fee under this notification.

The normal late fee structure, and why it was crippling

Under Section 47(1) of the CGST Act, the late fee for non-filing of GSTR-4 accrues at Rs. 200 per day (Rs. 100 CGST + Rs. 100 SGST), subject to a maximum of Rs. 5,000 (Rs. 2,500 CGST + Rs. 2,500 SGST) per return. A dealer who had missed five years of GSTR-4 faced a theoretical maximum of Rs. 25,000 before the amnesty. For a shopkeeper with a turnover of Rs. 40 lakh and nil tax payable, that penalty was existential.

The amnesty caps

Notification 02/2023-CT reduced the payable late fee for GSTR-4 filed between 1 April 2023 and 30 June 2023 to:

• Rs. 500 per return (Rs. 250 CGST + Rs. 250 SGST) where no tax was payable in that return
• Rs. 2,000 per return (Rs. 1,000 CGST + Rs. 1,000 SGST) where tax was payable

The late fee in excess of these caps was waived for returns filed within the window.

Filing GSTR-4 today (post-amnesty)

The amnesty window closed on 30 June 2023 and has not been renewed specifically for GSTR-4. If you have pending GSTR-4 returns for FY 2022-23 or later, the normal maximum late fee of Rs. 5,000 applies. Log in to the GST portal (www.gst.gov.in) → Returns → Annual Return → GSTR-4, select the relevant financial year, and the portal auto-computes the late fee at the time of filing. Never pay manually from your own calculation — the portal's figure is the operative one.

GSTR-9 Late Fee Rationalisation for Annual Returns (Notification 07/2023-CT)

The disproportionality problem

Before the 31 March 2023 notifications, GSTR-9 attracted the same Rs. 200 per day late fee as other returns, with a maximum of Rs. 10,000 (Rs. 5,000 CGST + Rs. 5,000 SGST). For a trader with an Annual Aggregate Turnover (AATO) of Rs. 80 lakh, a 90-day delay generated Rs. 18,000 in late fees — not because of tax evasion, but because of administrative neglect. The late fee was disproportionate to the risk represented by the taxpayer.

The turnover-linked slab structure

Notification 07/2023-CT rationalised the GSTR-9 late fee on a turnover-linked basis, which continues to govern filings in FY 2026-27:

Always verify the current maximum caps against the latest CBIC notification before computing liability, as these amounts have been subject to periodic revision. The GST portal applies the current notified rates automatically at the time of filing.

Note for GSTR-9C filers: If your AATO exceeds Rs. 5 crore, you must also file GSTR-9C — the reconciliation statement certified by a Chartered Accountant or Cost Accountant. A late GSTR-9 automatically means a late GSTR-9C; both attract separate late fees. File them together.

GSTR-10 Final Return: The Most Overlooked Post-Cancellation Trap

What GSTR-10 is — and who must file it

When a GST registration is cancelled — whether voluntarily on an application in Form GST REG-16, or suo motu by the proper officer — the registered person must file GSTR-10, the Final Return, within three months of the effective date of cancellation or the date of the cancellation order, whichever is later. GSTR-10 reports closing stock on which ITC was availed and computes the proportionate credit that must be reversed.

Many businesses cancel their GSTIN — particularly when winding down a venture or restructuring — and assume their compliance obligation ends on the date of cancellation. It does not. An unfiled GSTR-10 keeps the GSTIN in a technical default state and can create complications when you try to strike off the company on the MCA V3 portal.

The amnesty under Notification 08/2023-CT

For GSTR-10 returns not filed as of 28 February 2023, CBIC waived late fees in excess of Rs. 1,000 per return (Rs. 500 CGST + Rs. 500 SGST) for returns filed between 1 April 2023 and 30 June 2023.

Without this cap, a taxpayer who had delayed GSTR-10 by 300 days faced Rs. 200/day × 300 = Rs. 60,000 in accrued late fees (subject to the statutory maximum of Rs. 10,000). The amnesty reduced that to Rs. 1,000 — a saving of Rs. 9,000. For the thousands of small businesses that had cancelled their GSTINs during the pandemic years and never followed up, this was the difference between regularising their records and walking away from an unresolvable default.

Step-by-step: How to file GSTR-10 today

1. Log in to the GST portal using the cancelled GSTIN credentials — portal access persists even after cancellation for compliance purposes.
2. Navigate to Returns → Final Return → GSTR-10.
3. Report the details of goods held on the date of cancellation, including the ITC availed and the proportionate reversal required.
4. Pay the ITC reversal amount plus the auto-computed late fee via the payment ledger.
5. File using DSC (for companies and LLPs) or EVC (for proprietorships and partnerships).

Post-amnesty, the normal late fee applies — Rs. 200 per day with a statutory maximum of Rs. 10,000. Every day you delay filing a pending GSTR-10 today adds Rs. 200 to your liability and increases the risk of a Section 46 notice.

Revocation of Cancelled GST Registrations — The Special Window

The cancellation crisis of 2020–2022

From 2020 to 2022, CBIC's enforcement drive against persistent non-filers resulted in mass suo motu cancellations of GSTINs under Rule 21A of the CGST Rules. Many of those cancelled registrations belonged to genuine businesses temporarily disrupted by the pandemic. Once cancelled, they could not issue valid tax invoices, could not claim input tax credit, and in many cases lost contracts with large corporate buyers who required a valid GSTIN for their own ITC.

What Notification 03/2023-CT opened

The notification permitted taxpayers whose GST registrations had been cancelled on or before 31 December 2022 to apply for revocation by 30 June 2023, provided they:

1. Filed all pending returns — GSTR-1, GSTR-3B, GSTR-4 (for composition dealers), GSTR-7, GSTR-8 as applicable — from the date of registration to the date of cancellation.
2. Paid all outstanding tax, interest under Section 50, and applicable late fees.
3. Filed a revocation application in Form GST REG-21 through the GST portal.

CBIC subsequently extended the deadline through further notifications. Before filing today, check the latest CBIC circular at cbic.gov.in to confirm the current extended deadline.

What happens after you submit REG-21

The proper officer reviews the application and all pending return filings. If satisfied, the officer revokes the cancellation order and restores the GSTIN to active status. If not satisfied, a show-cause notice in Form GST REG-23 is issued; you have 7 working days to respond in Form GST REG-24. On successful revocation, your GSTIN becomes active from the date of the revocation order — not retrospectively from the date of cancellation. You cannot issue backdated tax invoices or claim ITC for the period the GSTIN was cancelled.

The 2026 overlay: biometric authentication

Under the amended rules notified through Finance Act 2026, all revocation applications now trigger mandatory biometric Aadhaar authentication for every promoter and authorised signatory listed on the registration. In designated high-risk states, a physical verification of the business premises must also be completed before the GSTIN is reinstated. Budget extra time — approximately 2 to 4 weeks beyond the filing date — for this verification to be completed.

Section 62 Best-Judgement Assessments — You Have 30 Days, No More

How Section 62 creates liability out of silence

Section 62 of the CGST Act authorises the proper officer to issue a best-judgement assessment order against a registered taxpayer who fails to file a return even after a notice under Section 46. The officer uses available data — GSTR-2B credits visible to the taxpayer's counterparties, e-way bill records, third-party supply data on the GSTN — to estimate the tax liability and issue an order accordingly. These estimates are routinely higher than actual liability.

The 31 March 2023 notifications extended the period within which a non-filer could neutralise a Section 62 order by simply filing the pending return. This remains one of the most underused provisions in the CGST Act.

The 30-day rule — and what it costs you to miss it

Once a Section 62 assessment order is served on you, the clock starts. You have 30 days to:

1. File the pending return for the assessed period.
2. Include all tax, interest under Section 50 at 18% per annum on the net cash liability from the due date of payment to the actual date of payment, and the applicable late fee.
3. The assessment order is automatically deemed withdrawn — no hearing, no appeal, no separate order is needed.

Miss the 30-day window and the order becomes a confirmed demand recoverable under Section 79. That means attachment of bank accounts, recovery from debtors, and eventually sale of attached property — consequences that dwarf the original tax liability.

Important Section 50 nuance: Since the 2021 amendment to Section 50(3), interest on delayed GSTR-3B filing is computed on the net cash liability — that is, tax payable minus ITC available in the electronic credit ledger on the due date. Do not compute interest on gross tax. An error here can mean either over-payment or, worse, an interest deficit that the department will demand later.

What to do on receiving a Section 62 order in 2026

• Verify the date of service printed on the order, not the date you discovered it.
• Log in to the GST portal immediately and check the GSTR-2B for the period in question.
• Prepare the GSTR-3B from your own books, cross-referencing against GSTR-2B, and compute interest at 18% per annum on the net cash shortfall.
• File and pay within 30 days. Keep a screenshot of the filing confirmation.
• Follow up with the jurisdictional officer to confirm the deemed withdrawal has been recorded in the system.

Worked Example: A Composition Dealer Clearing Four Years of Pending GSTR-4

Scenario: Vijay General Stores is a composition scheme dealer in Rajasthan (goods), AATO approximately Rs. 45 lakh per year. They missed GSTR-4 for FY 2018-19, FY 2019-20, FY 2020-21 and FY 2021-22 — four returns. No tax was payable in any of the four years. They also cancelled their GSTIN in November 2022 and never filed GSTR-10.

Step 1 — Late fee exposure for GSTR-4 under the normal regime

Maximum late fee per return: Rs. 5,000 (Rs. 2,500 CGST + Rs. 2,500 SGST) Four missed returns × Rs. 5,000 = Rs. 20,000

Step 2 — Late fee under the 2023 amnesty (nil tax returns)

Amnesty cap per return: Rs. 500 (Rs. 250 CGST + Rs. 250 SGST) Four returns × Rs. 500 = Rs. 2,000

Saving on GSTR-4 alone: Rs. 18,000

Step 3 — GSTR-10 exposure (filed 180 days after the 3-month deadline)

Normal late fee: Rs. 200/day × 180 days = Rs. 36,000 (capped at statutory maximum of Rs. 10,000) Under 2023 amnesty: Rs. 1,000

Saving on GSTR-10: Rs. 9,000

Step 4 — Total amnesty saving

Rs. 18,000 (GSTR-4) + Rs. 9,000 (GSTR-10) = Rs. 27,000 total saving by filing within the 2023 amnesty window.

The 2026 equivalent — what Vijay would pay today

The amnesty is closed. Filing the same four GSTR-4 returns and the GSTR-10 today means Rs. 20,000 (GSTR-4) + Rs. 10,000 (GSTR-10) = Rs. 30,000 in late fees — fifteen times the amnesty amount. The cost of delay is now real and compounding.

Common Mistakes Taxpayers Still Make in 2026

1. Assuming the 2023 amnesty rates still apply

The 1 April–30 June 2023 window is closed. Taxpayers who missed it cannot claim the capped rates retroactively. Every late return filed today is subject to current statutory maximums. Do not look at a three-year-old article and apply those figures — always check the GST portal's auto-computed late fee at the time of filing.

2. Filing GSTR-10 with an incorrect ITC reversal

GSTR-10 requires reversal of ITC on closing stock not consumed before cancellation. A common error is reporting the purchased cost of goods rather than the proportionate ITC on that stock. The department's automated reconciliation engine cross-references GSTR-10 ITC reversals against GSTR-3B and GSTR-2B data. Discrepancies generate automatic DRC-01A notices.

3. Treating a revoked GSTIN as retrospectively active

Revocation is effective from the date of the revocation order, not the original registration date. You cannot issue tax invoices for the suspension period, and you cannot claim ITC for purchases made while the GSTIN was cancelled — even if those purchases are otherwise eligible.

4. Missing the 30-day Section 62 window because of outdated portal contact details

Section 62 orders and SCNs are served electronically on the GST portal and simultaneously by email and SMS to the registered mobile and email. If your portal profile still shows an old phone number or a defunct email, you will miss the notice — and the 30-day clock will still run from the date of service, not the date you discover the order. Update your contact details in the GST portal today under My Profile → Edit Contact Details.

5. Omitting Section 50 interest when filing a delayed GSTR-3B

Late fee and tax are entered separately in the payment ledger. Interest under Section 50 must be self-computed and added as a separate line. Many taxpayers pay the tax and the late fee but skip the interest column. The resulting deficit creates a fresh interest demand that is harder to dispute than a proactive payment.

6. Not reconciling GSTR-2B before filing GSTR-9

From FY 2022-23, ITC declared in GSTR-9 must be consistent with GSTR-2B. Discrepancies automatically trigger DRC-01C notices. Before filing GSTR-9 for FY 2025-26, download your GSTR-2B month by month, reconcile it against your purchase register, reverse any ITC on which suppliers have not filed GSTR-1, and then file GSTR-9. Reconciliation after filing is far more expensive than reconciliation before.

How the 2026 Framework Has Inherited the 2023 Philosophy

The 31 March 2023 notifications established a recurring pattern: CBIC offers a time-limited window to regularise defaults at reduced cost, then enforces the full penalty regime once the window closes. That pattern has crystallised into permanent structures by FY 2026-27.

Section 128A Settlement Scheme: For confirmed demands, interest and penalties relating to periods up to 31 March 2024, this scheme allows settlement by paying only the principal tax demand — interest and penalties are waived if you comply within the notified window. Think of it as the GSTR-9/GSTR-10 amnesty logic applied to adjudicated demands.

Automated nil-filer late fee waivers: CBIC periodically issues circulars that automatically waive late fees for nil GSTR-3B returns filed within a concessional period at the start of each quarter. Monitor CBIC circulars at the beginning of every quarter and file pending nil returns within those windows.

Biometric Aadhaar authentication — now standard: All new registrations in designated high-risk states require biometric authentication under Rule 8(4A) of the CGST Rules. For revoked registrations being reinstated, all promoters and authorised signatories must complete biometric verification at a GST Suvidha Kendra before the GSTIN goes live. Factor in 2 to 3 weeks for this process.

Tighter AIS/TIS-style cross-matching on GSTN: The GST portal now runs near-real-time reconciliation between GSTR-1 filed by suppliers and GSTR-2B generated for recipients. ITC discrepancies above the tolerance limit are flagged immediately. The era of claiming ITC on invoices not yet reflected in GSTR-2B is over.

Key Takeaways

• The 2023 amnesty windows closed on 30 June 2023. GSTR-4, GSTR-9 and GSTR-10 filed today attract current statutory late fees — there is no grandfathering of the 2023 reduced rates.
• GSTR-10 is a mandatory, time-bound obligation. Every cancelled GSTIN must file its final return within three months of cancellation; each day of delay adds Rs. 200 to the late fee up to the statutory cap of Rs. 10,000.
• Section 62 orders carry a hard 30-day response window. File the pending return within 30 days of service — with tax, Section 50 interest at 18% per annum on the net cash liability, and late fee — to get the assessment deemed withdrawn automatically.
• Revocation restores a GSTIN prospectively, not retrospectively. You cannot issue backdated invoices or claim ITC for the period of cancellation; biometric Aadhaar authentication for all promoters is now mandatory before reinstatement.
• Section 128A settlement scheme is the active mechanism for resolving pre-FY 2024-25 confirmed GST demands — use it before adjudication proceedings advance to recovery under Section 79.
• Reconcile GSTR-2B against your purchase register before filing GSTR-9, not after. Post-filing DRC-01C notices are harder and costlier to resolve than a proactive reconciliation exercise.
• Update your GST portal contact details today. Every compliance notice — Section 46, Section 62, DRC-01A — is served electronically to the registered mobile and email. Stale contact information means missed notices and missed deadlines.