☐ Is GSTR-3B filed by 20th of next month (or QRMP framework)? ☐ Has reconciliation with GSTR-1 been done? ☐ Has reconciliation with GSTR-2B been done? ☐ Has sequencing discipline under sub-s. (10) been observed? ☐ Has tax payment under…
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☐ Is GSTR-3B filed by 20th of next month (or QRMP framework)? ☐ Has reconciliation with GSTR-1 been done? ☐ Has reconciliation with GSTR-2B been done? ☐ Has sequencing discipline under sub-s. (10) been observed? ☐ Has tax payment under…
Section 39 GSTR-3B compliance — checklist (19 items)
Section 39 GSTR — 3B compliance — checklist (19 items)
☐ Is GSTR-3B filed by 20th of next month (or QRMP framework)?
☐ Has reconciliation with GSTR-1 been done?
☐ Has reconciliation with GSTR-2B been done?
☐ Has sequencing discipline under sub-s. (10) been observed?
☐ Has tax payment under sub-s. (7) been done by due date?
☐ For QRMP, has PMT-06 monthly payment been done?
☐ For errors, has rectification under sub-s. (9) been done?
☐ Has 30-November outer limit for rectification been observed?
☐ For scrutiny / audit-detected omissions, has s. 73/74 framework been considered?
☐ Has coordination with s. 16 ITC conditions been done?
☐ Has coordination with s. 38 GSTR-2B framework been done?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Vatika prospective-operation been applied?
☐ Has documentary trail been preserved?
☐ Has Whirlpool framework been considered for disputes?
☐ Has coordination with broader compliance framework been done?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Standard GSTR-3B filing
Facts: Taxpayer files GSTR-3B for August 2025 by 20-Sep-2025 with reconciled GSTR-1 + GSTR-2B + tax payment.
Analysis: Sub-s. (1) compliance. Sub-s. (7) payment. Sub-s. (10) sequencing maintained. Standard discipline.
Result: Compliant.
Example 2 — Sequencing breach
Facts: Taxpayer skipped July 2025 GSTR-3B. Attempts August 2025 filing.
Analysis: Sub-s. (10) — sequencing discipline. Cannot file August without July. Practitioner advice — file July first + late fee under s. 47.
Result: Sequencing discipline.
Example 3 — Self-detected rectification
Facts: FY 2024-25 supply missed in original GSTR-3B. Discovered Sep 2025.
Analysis: Sub-s. (9) — self-detected. Rectify in subsequent return + pay tax + interest under s. 50. 30-November 2025 outer limit observed.
Result: Rectification framework operates.
Example 4 — Scrutiny-detected omission
Facts: Department scrutiny detects omission for FY 2023-24.
Analysis: Sub-s. (9) rectification excludes scrutiny-detected omissions. s. 73 framework — SCN within 3 years from due date of annual return + s. 168A extensions. Practitioner defence — substantive merits framework.
Result: s. 73 framework operative.
Example 5 — QRMP framework
Facts: Taxpayer turnover Rs. 3 cr. Opts for QRMP.
Analysis: Quarterly GSTR-3B + monthly PMT-06 payment + monthly IFF for B2B. Notification 1/2021-CT framework.
Result: QRMP framework operative.
Planning and litigation strategy
Litigation defence
Cross-references