Rule 37A ITC Reversal for FY 2025-26: A CA Checklist

The 30 September check has passed. What should teams do now?

For input tax credit availed during FY 2025-26, Rule 37A asks recipients to check whether suppliers filed the corresponding GSTR-3B by 30 September 2026. Where the relevant supplier return was not filed by that date, the recipient must reverse the corresponding credit in a GSTR-3B furnished on or before 30 November 2026.

The clock is linked to the financial year in which the recipient availed the ITC. It is not simply based on the invoice date. That distinction can move an invoice into a different Rule 37A review cycle than a team expects.

What Rule 37A actually tests

The rule covers ITC that the recipient has already availed in GSTR-3B for an invoice or debit note whose details the supplier furnished in GSTR-1, as amended in GSTR-1A if any, or through the Invoice Furnishing Facility. The test is whether the supplier furnished the GSTR-3B for the tax period corresponding to that outward-supplies statement by 30 September following the financial year in which the recipient availed the credit.

If that supplier return was not furnished by the cut-off, the recipient has to reverse the relevant ITC in a GSTR-3B return on or before 30 November following that financial year. If the reversal is not made by that date, Rule 37A says the amount is payable with interest under Section 50. If the supplier later furnishes the corresponding GSTR-3B, the recipient may re-avail the credit as permitted by the rule. See Rule 37A in Notification No. 26/2022-Central Tax and the subsequent GSTR-1A amendment in Notification No. 12/2024-Central Tax.

The FY 2025-26 timeline

What to check	Rule 37A date for ITC availed in FY 2025-26
Supplier filing check	Corresponding GSTR-3B filed by 30 September 2026
Recipient reversal, where required	In a GSTR-3B furnished on or before 30 November 2026
Later supplier filing	Review eligibility to re-avail the reversed credit

For example, suppose an invoice dated March 2025 was claimed in the recipient’s GSTR-3B for April 2025. The ITC was availed in FY 2025-26, so its Rule 37A review falls in the FY 2025-26 cycle. The relevant supplier GSTR-3B filing check was 30 September 2026, even though the invoice itself is dated in the previous financial year.

Why a GSTR-2B match does not finish the check

GSTR-2B helps identify invoice details furnished by suppliers. Rule 37A also requires checking whether the supplier filed the corresponding GSTR-3B. A record appearing in GSTR-2B should not, on its own, be treated as proof that the corresponding supplier return was filed by the Rule 37A cut-off.

Start with ITC actually availed in the recipient’s GSTR-3B, then identify the invoices and debit notes in scope. Check the supplier’s corresponding GSTR-3B filing status for the relevant period using the GST portal’s available information. Match that result to the recipient’s claim history before deciding whether a reversal is required. Keep a record of the working, the return periods reviewed, the amount considered, and the action taken.

A practical review before the November return

List invoices and debit notes for which ITC was availed during FY 2025-26. Do not treat every item in GSTR-2B as a Rule 37A reversal candidate if the credit was never availed.
For each supplier document in scope, identify the corresponding outward-supplies statement and tax period.
Check whether the supplier furnished the corresponding GSTR-3B by 30 September 2026. Keep this separate from other reasons an invoice may be unmatched or ineligible.
Calculate the credit requiring reversal based on the records and applicable facts, then include the required reversal in a GSTR-3B furnished by 30 November 2026.
If the supplier files later, reassess re-availment under Rule 37A and retain the supporting records.

This is a focused Rule 37A check, not a substitute for reviewing other ITC conditions, restrictions, or reversal rules. If the supplier-period mapping or amount is uncertain, resolve it with the taxpayer’s records and a qualified GST professional before filing.

What Invozen does and does not do

Invozen supports purchase invoice and GSTR-2B reconciliation. It does not check whether a supplier filed the corresponding GSTR-3B for Rule 37A, calculate Rule 37A reversals, or create a Rule 37A compliance task list. The supplier filing-status check, determination of credit availed, and return action remain part of the taxpayer’s or advisor’s review.