Indirect Tax News Letter- March 2026
GST Calendar –Compliances for the month of March ’2026
| Nature of Compliances | Due Date |
| GSTR-7 (Tax Deducted at Source ‘TDS’) | April 10, 2026 |
| GSTR-8 (Tax Collected at Source ‘TCS’) | April 10, 2026 |
| GSTR-1 | April 11, 2026 |
| IFF- Invoice furnishing facility (Availing QRMP) | April 13, 2026 |
| GSTR-6 Input Service Distributor | April 13, 2026 |
| GSTR-2B (Auto Generated Statement) | April 14, 2026 |
| GSTR-3B | April 20, 2026 |
| GSTR-5 (Non-Resident Taxable Person) | April 20, 2026 |
| GSTR-5A (OIDAR Service Provider) | April 20, 2026 |
| PMT-06 (who have opted for QRMP scheme) | April 25, 2026 |
GST Changes from 1st April 2026: New Rules and Updates
The amendments under the Goods and Services Tax regime effective from 1st April 2026 encompass both procedural compliances applicable at the commencement of the financial year and substantive statutory modifications. It is imperative that taxpayers duly undertake year-beginning compliances, including, inter alia, furnishing of the Letter of Undertaking (LUT) for Financial Year 2026–27, adherence to e-invoicing requirements, and compliance with obligations under the Invoice Management System (IMS).
Key Highlights:
- Taxpayers engaged in export of goods or services, or supplies to SEZ units without payment of Integrated GST, are required to furnish a fresh LUT for FY 2026–27 prior to issuance of any export invoice.
- The erstwhile minimum threshold limit of ₹1,000 for processing export refund claims has been dispensed with, thereby enabling processing of all valid refund claims irrespective of amount.
- A new and distinct document series for invoices, debit notes, and credit notes is mandatorily required to be initiated from 1st April 2026.
Detailed Amendments:
- Furnishing of LUT for FY 2026–27
The LUT filed for FY 2025–26 shall cease to be valid post 31st March 2026. Accordingly, taxpayers must furnish Form RFD-11 prior to issuance of the first export invoice for FY 2026–27, failing which IGST shall be payable on export supplies, subsequently claimable as refund, thereby adversely impacting working capital.
- Removal of Export Refund Threshold
The restriction on processing refund applications below ₹1,000 has been withdrawn. Consequently, all admissible refund claims, irrespective of quantum, shall be eligible for processing.
- Fresh Document Numbering Series
Taxpayers are required to commence a new series for all tax documents, including invoices, debit notes, and credit notes, from 1st April 2026. Continuation of the previous financial year’s series may lead to reconciliation discrepancies and potential departmental scrutiny.
- E-Invoicing Compliance
E-invoicing shall be mandatory for taxpayers whose aggregate annual turnover exceeds ₹5 crores in FY 2025–26. Further, for taxpayers with turnover exceeding ₹10 crore, invoices must be reported on the Invoice Registration Portal within 30 days, failing which such invoices shall be rendered invalid for input tax credit purposes.
- Electronic Credit Reversal and Reclaimed Statement (ECRS)
Taxpayers must ensure accurate reporting of input tax credit reversals and reclaims at the document level. A negative balance in ECRS may, in due course, result in restriction on filing of GST returns.
- GTA Services – Forward Charge Mechanism
In cases where Goods Transport Agencies opt for payment of tax under forward charge, it is essential for recipients to obtain a valid declaration for FY 2026–27. In absence thereof, liability to discharge tax shall devolve upon the recipient under reverse charge.
- Invoice Management System (IMS) Compliance
- Credit notes reported must be promptly communicated to recipients to avoid rejection, which may otherwise result in additional tax liability.
- Rejected credit notes from vendors necessitate appropriate corrective action, as they impact input tax credit entitlement.
- Amendment under Rule 14A of CGST Rules
The condition for withdrawal from registration under Rule 14A has been relaxed. Filing of returns for one complete tax period shall now suffice, as opposed to the earlier requirement of three months.
Madras High Court – On ISD Credit Distribution
Facts:
The petitioner, being a registered taxpayer operating under multiple GST registrations and functioning as an Input Service Distributor (ISD), was subjected to proceedings on account of alleged non-compliance with Rule 39(1)(a) of the CGST Rules, 2017. The allegation pertained to failure in distributing input tax credit (ITC) within the same tax period in which the underlying invoices were received. The petitioner challenged the validity and interpretation of the said Rule, particularly in light of the statutory framework governing availment and distribution of ITC under Sections 16 and 20 of the CGST Act.
Issue:
The principal question for consideration was whether ITC is mandatorily required to be distributed by an ISD in the same month of receipt of invoices in terms of Rule 39(1)(a), irrespective of whether the substantive conditions prescribed under Section 16(2) for availment of ITC have been duly satisfied, and consequently, whether the said Rule travels beyond or remains within the scope of the parent statute.
Held:
The Hon’ble High Court, adopting a purposive and harmonious construction of the statutory provisions, held that entitlement to ITC arises only upon fulfillment of the conditions stipulated under Section 16(2), and therefore, the expression “input tax credit available for distribution” under Rule 39(1)(a) must be construed to mean credit that has become legally admissible. It was accordingly held that distribution of ITC cannot be mandated merely upon receipt of invoices, but only upon crystallization of entitlement. Consequently, the Rule was upheld as intra vires when so interpreted, and it was clarified that distribution need not necessarily occur in the same month as invoice receipt, but in the period in which the taxpayer becomes eligible to avail such credit.
Concessional Levy of Customs Duty on Goods Manufactured by SEZ Units and Cleared to DTA.
A notification has been issued by the competent authority prescribing a concessional rate of Basic Customs Duty (BCD) and Agriculture Infrastructure and Development Cess (AIDC) in respect of specified goods manufactured by units operating in Special Economic Zones (SEZ) and subsequently cleared into the Domestic Tariff Area (DTA). The said benefit is operative for a limited duration commencing from 1 April 2026 up to 31 March 2027.
The applicability of the concessional regime is restricted to those SEZ units which had commenced production on or before 31 March 2025. The benefit is expressly excluded in respect of Free Trade Warehousing Zones (FTWZ) and in cases where goods, after import into the SEZ, are cleared into DTA either in the same form or after usage, without undergoing the prescribed manufacturing process.
Further, the concession is subject to fulfilment of stipulated substantive and procedural conditions. Inter alia, the goods must satisfy a minimum value addition threshold of 20%, and the aggregate value of clearances into DTA in a financial year shall not exceed 30% of the highest FOB value of exports achieved in any of the preceding three financial years. Additionally, no duty drawback or export incentive under the Foreign Trade Policy should have been availed in respect of inputs used in such goods.
From a procedural standpoint, the SEZ unit is required to file a bill of entry for home consumption on the common portal, which shall be subject to assessment by the proper officer. At the time of clearance, certification from the jurisdictional Development Commissioner is required to substantiate compliance with conditions relating to commencement of production, export performance, and value addition. Further, the unit is obligated to furnish an undertaking for payment of differential duty in the event of non-fulfilment of prescribed conditions.
The measure is intended to facilitate disposal of accumulated inventory by SEZ units into the domestic market, particularly in light of prevailing global trade constraints. However, the requirement of filing the bill of entry by the SEZ unit itself gives rise to a potential issue of dual levy of Integrated GST, both at the stage of import clearance and under the GST framework treating the transaction as a supply, which may warrant further