New GSTR-1 and GSTR-3B Formats From April 2027: What the Draft Changes, and What to Tell CBIC Before 30 November
By GST Reco Pro
GST Reco Pro builds browser-based tools for GST and TDS reconciliation, used by Chartered Accountants and corporate tax teams across India.
CBIC's draft return changes, open for comment on MyGov until 30 November 2026, would make GSTR-1 the only place to correct outward liability and GSTR-2B the only source of normal ITC from the April 2027 return period. Here is what the draft does, table by table, and the comments worth sending.
The GST Council's 57th meeting on 8 October 2026 approved what CBIC calls an alternate mechanism for amending tax liability and input tax credit inside the return system. The draft rules, forms and a circular went up on MyGov for public comment from 1 to 30 November 2026, and the changes are proposed to apply from the April 2027 return period. Returns up to March 2027 stay on the current forms.
The idea is simple to state. GSTR-3B should stop being a place where numbers are typed in. Outward liability should come from GSTR-1, as corrected through GSTR-1A or IFF, and normal input tax credit should come from GSTR-2B, as shaped through the Invoice Management System. If a figure is wrong, you fix it at the source, not in GSTR-3B.
Why CBIC is doing this
Most system-generated GST intimations come from two comparisons: GSTR-1 against GSTR-3B for liability (DRC-01B, Rule 88C) and GSTR-2B against GSTR-3B for ITC (DRC-01C, Rule 88D). Both exist because GSTR-3B, although it is auto-populated, can still be edited before filing. Every edit is a potential mismatch. The tools to correct data at the source, such as GSTR-1A, IMS and the credit reversal and reclaim statement, already exist, but apart from GSTR-1A most of them are portal features rather than rules. The draft puts them into the CGST Rules and makes them the only route.
The rules that change the workflow
| Proposed provision | What it does | What it means in practice |
|---|---|---|
| Rule 61(1A) | Outward supplies in GSTR-3B must not differ from GSTR-1 as amended by GSTR-1A or IFF | No more fixing liability in Table 3.1. An error from an earlier period is corrected through the outward statement of the period in which it is noticed |
| Rule 61(1B) | Normal (non-reverse-charge) ITC in GSTR-3B must match GSTR-2B | ITC is shaped in IMS before GSTR-2B is generated, not edited in Table 4 |
| New proviso to Rule 61(1) | Where normal ITC is claimed, GSTR-3B can be filed only after that period's GSTR-2B is available | No filing GSTR-3B early on the strength of your own purchase register |
| Rule 60(6A) | IMS written into the rules: accept, reject or keep pending; no action by GSTR-3B filing means deemed acceptance | Pending is a deliberate choice with a time limit, not a parking lot |
| New Rule 86C and 86D | Statutory statements for ITC reversed and reclaimed (PMT-02A) and for reverse charge tax paid versus ITC claimed (PMT-02B) | Reclaims and reverse charge ITC are capped by a running ledger balance |
GSTR-1 and GSTR-1A
GSTR-1 gets more granular so that the portal can place every figure in the right GSTR-3B table without guesswork. The notable changes in the draft:
- Table 4 (B2B) is split further. Supplies made through an e-commerce operator that collects TCS get their own row (4E), separate from regular, reverse charge and SEZ supplies.
- Tables 5 and 7 (B2C) separate e-commerce TCS supplies from direct ones, and Table 7 splits intra-State B2C supplies from inter-State B2C supplies up to ₹1 lakh, with place of supply.
- Table 9 (amendments, credit and debit notes) gains a drop-down saying which original table an amendment relates to, so GSTR-3B can reduce the right line.
- Table 11 (advances) lets an advance be tagged to the table of the eventual supply.
- Table 12 (HSN) is split into supplies to registered and unregistered persons, with a new Table 12A to amend an earlier period's HSN summary.
- A new Table 8AA allows nil-rated, exempt and non-GST supplies of earlier periods to be amended.
- Suppliers may voluntarily link credit and debit notes to the original invoices.
GSTR-1A becomes the main correction tool. Today it only amends the current period. The draft lets it amend or add details for the current period or an earlier one, subject to the Section 37(3) time limit, and allows a wrong recipient GSTIN to be corrected. It opens after the GSTR-1 due date or the actual GSTR-1 filing date, whichever is later, and stays open until GSTR-3B is filed. It remains optional and carries no late fee. Supplies added through GSTR-1A reach the recipient's next open GSTR-2B.
GSTR-2B, IMS and GSTR-3B
- Draft GSTR-2B is generated on the 14th of the following month, and only if the previous period's GSTR-3B has been filed. A taxpayer who is behind cannot get the next GSTR-2B until they catch up.
- A revised GSTR-2B can be requested after IMS actions taken post-generation, before GSTR-3B is filed.
- A new GSTR-2B Table 6 lists invoices and credit notes rejected in IMS, so rejected documents are visible rather than simply absent.
- If the recipient rejects a credit note, the tax goes back onto the supplier's liability in the next return, with interest from the due date of the original period.
- GSTR-3B gets a new Table 4(AA) for ITC reclaimed after an earlier temporary reversal, instead of routing reclaims through 4(A)(5) and 4(D)(1). The reclaim cannot exceed the PMT-02A balance.
- A new PMT-10 lets a taxpayer correct an excess permanent reversal made in Table 4(B)(1) of an earlier return, within the Section 39(9) time limit.
DRC-03 Part B: fixing the double-liability problem
Today, when a supplier pays tax through DRC-03 after an audit or scrutiny and then reports the related invoice in GSTR-1 so the buyer can claim credit, the same tax lands in GSTR-3B again. The usual workaround is to edit GSTR-3B down, which creates the very mismatch the system flags. The draft adds a Part B to DRC-03, to be filed within seven days of the Part A payment, listing the registered recipients and invoices. Part B populates GSTR-1 directly, cannot be edited there, and does not add the tax to GSTR-3B a second time. The buyer gets the credit through GSTR-2B.
Comments worth sending before 30 November
The consultation is the only point at which practitioners can shape the operational detail. A comment is more useful when it describes a concrete situation the draft does not handle. Areas that deserve scrutiny:
- The GSTR-2B gate. Making GSTR-2B depend on the previous GSTR-3B being filed can lock a taxpayer who missed one month out of credit for every month after it. Ask for a catch-up path.
- GSTR-1A timing for quarterly filers. Check how the window works for QRMP taxpayers who also file IFF, and whether a correction found after GSTR-3B is filed must wait a full period.
- Deemed acceptance in IMS. Silence becomes acceptance at GSTR-3B filing. Ask whether there will be a warning before deemed acceptance, especially for credit notes that reduce ITC.
- Transition. Ask how amendments made after April 2027 to invoices of earlier periods will be reported, and how opening balances for PMT-02A and PMT-02B will be set.
- The Table 9 drop-down. Mapping every amendment to its original table is extra work on high-volume returns. Ask for bulk upload and API support.
- DRC-03 Part B's seven-day window. Audit and scrutiny payments often cover many invoices across many recipients. Ask whether seven days is realistic.
Practitioners report that submitted suggestions cannot be edited, so draft the comment offline and submit it once.
What to change in your practice now
April 2027 is close enough that habits formed this year will carry over. Three changes are worth making early. Stop treating GSTR-3B as the place to fix errors, and correct liability through GSTR-1A today wherever the current rules allow. Clear IMS every month rather than at the deadline, because inaction already means deemed acceptance, and the draft writes that into the rules. And keep a monthly GSTR-1 versus GSTR-3B comparison by tax head for every client, because if the draft is notified as proposed, any difference you cannot explain from April 2027 will be one you are no longer allowed to make.
The new regime rewards practices that already compare GSTR-1 and GSTR-3B every month. GST Reco Pro converts both returns into one Excel workbook with tax by head for each period, entirely in your browser, so the comparison takes minutes instead of an afternoon of re-keying.
Convert GSTR-1 and GSTR-3B PDFs to Excel →Related reading: until the new mechanism takes effect, liability mismatches still produce DRC-01B intimations. Here is how to reply within the seven days.
Read the DRC-01B reply guide →Related reading: a working IMS routine for accepting, rejecting and keeping invoices pending, which the draft makes central.
Read the IMS workflow guide →Frequently Asked Questions
When do the new GST return forms apply?
The draft changes are proposed to apply from the April 2027 return period. Returns for periods up to March 2027 continue on the current forms. The changes are not law until the rules and forms are notified.
How do I comment on the draft GST return forms?
The consultation is on MyGov from 1 to 30 November 2026. Read the consultation note there, prepare your comment offline, and submit it through the MyGov consultation page before 30 November. Practitioners report that a submitted suggestion cannot be edited.
Will I still be able to edit GSTR-3B after April 2027?
The draft does not say the fields will be technically locked, but proposed Rule 61(1A) requires outward supplies in GSTR-3B to match GSTR-1 as amended through GSTR-1A or IFF, and Rule 61(1B) requires normal ITC to match GSTR-2B. In effect, corrections move to GSTR-1, GSTR-1A, IFF and IMS.
What changes in GSTR-1A under the draft?
GSTR-1A would be able to amend or add details for earlier periods as well as the current one, subject to the Section 37(3) time limit, and to correct a wrong recipient GSTIN. It would open after the GSTR-1 due date or filing date, whichever is later, and stay open until GSTR-3B is filed.
What are PMT-02A, PMT-02B and PMT-10?
PMT-02A is a statutory statement of ITC temporarily reversed and later reclaimed. PMT-02B tracks reverse charge tax paid against reverse charge ITC claimed. PMT-10 is a new application to correct an excess permanent ITC reversal made in an earlier GSTR-3B. All three are part of the draft.