Points To Be Taken Care Of Before End Of Financial Year 2024-25, I.e., 31st March, 2025| Part-1


As the last date of the Financial Year 2024-25 is approaching, it is imperative for every business to undertake various measures to ensure the seamless operation of their activities and to maintain legal compliance. Businesses need to take care of various aspects such as payments to MSMEs, Filing of forms and declarations with the authority, etc. before the commencement of the new financial year.

Following are the key action points that need to be taken care of before the end of the Financial year:

1. Payment to MSME for claiming deduction under Section 43B(h) of Income Tax Act, 1961:

  • As per Section 43B(h) of Income Tax Act, 1961, any entity liable to make payment to Micro and small enterprises (SME) (Not Medium enterprises) shall make the payment before the due date specified under Section 15 of MSME Act to claim deductions under Section 43B(h) of Income Tax Act.
  • If any sum is payable to the MSE at the end of the financial year and payment of such amount is made beyond the due date, as specified under MSME Act, then deduction for expense shall be allowed during the year in which payment is made.
  • Following are the due dates of making payment under MSME Act:
Criteria Due date of Payment
Where a period is agreed upon between the buyer and seller The Buyer shall make the payment on or before the agreed due date(Agreed period shall not exceed 45 days from the date of acceptance)
Where no period is agreed between the buyer and the seller Within 15 days from the date of acceptance
  • Any addition under Section 43B(h) can result in huge Income Tax liability. Therefore, it is suggested to clear the due before the specified due date for claiming deductions. 

2. Filing of Letter of Undertaking for export of goods without payment of IGST

  • Under Goods and Service Tax, the exporter is allowed to export goods or services without payment of IGST subject to filing of Letter of Undertaking (“LUT”) with GST authorities. If any export is made without filing of LUT, then the exporter is liable to pay IGST on export of goods and services.
  • A separate LUT is filed for every financial year. Therefore, as the new Financial year is about to commence, the exporters are required to file a new LUT before 31st March, 2025 for FY 2025-26.
  • LUT can be filed post login at the GST portal by furnishing details of two witnesses. LUT is not required to be accompanied with any Bank Guarantee. 

3. Furnish Annexure-V by Goods Transport Agencies (GTA)

  • In earlier years, the GST on GTA services was payable under Reverse Charge Mechanism, i.e., GST was required to be paid by the service recipient under RCM.
  • However, the GTA provisions have undergone a drastic amendment with effect from 18th July, 2022. Post July, 2022, the GTA was given an option to pay GST under Forward Charge or Reverse Charge Mechanism. However, to exercise this option, the GTA is required to furnish a declaration in Form Annexure-V.
  • Annexure-V can be filed post login at GST portal. Accordingly, the GTA shall have the following options under Annexure-V:
    • Payment of GST under Forward Charge Mechanism;
    • Payment of GST under Reverse Charge Mechanism;
  • If the GTA opts for payment of GST under Forward charge, then GST can be charged at either of the following Rates:
    • 5%: No ITC of Inward supplies shall be available to the GTA;
    • 12%: ITC of inward supplies shall be available to the GTA
  • Option can be opted by filing a declaration in Annexure-V post login on the GST portal. Such annexure is to be filed before 31st March, 2025 for FY 2025-26.

4. Filing of Pending Form GSTR-9C upto FY 2022-23

  • There are many taxpayers who have filed form GSTR-9 but did not file Form GSTR-9C. So, the GST Department has opened an amnesty scheme for filing of pending Form GSTR-9C up to FY 2022-23 up to 31st March, 2025.

Read Also: Recommendations of the 55th GST Council Meeting| Changes and Clarification on GST Rates

  • As per Notification No. 08/2025-Central Tax dated 23rd January 2025, the government has granted the following relief from a  late fee on filing of GSTR-9C:
    • the late fee in respect of delayed filing of complete annual returns (i.e., GSTR-9 and GSTR-9C) for any financial year up to FY 2022-23 has been waived, which is over the late fee payable up to the date of furnishing of return in FORM GSTR-9.
    • The condition for claiming waiver is that all pending GSTR-9C up to FY 2022-23 are required to be furnished by 31st March 2025.

E.g. For FY 2020-21, 

Due date of filing of GSTR-9 and GSTR-9C 31st December, 2021
GSTR-9 Filing date 31st January, 2022
GSTR-9C Filing date 28th February, 2025
Late Fee payable as per Section 47(2) of CGST Act For the period of 1st January, 2022 till 28th February, 2025
Waiver as per N/No. 08/2025- Central Tax Dated 23rd January, 2025 Late fee waived for the period of 1st February 2022 till 28th February 2025

5. Tax Saving Investments

There are many investments which are solely made for the purpose of saving taxes under the Income tax Act. However, the date of making such an investment is the most crucial for claiming the benefits. As the year-end is approaching, all taxpayers are required to make payments for tax saving investments, donations, etc. before 31st March, 2025.

Any payment made from 1st April, 2025 onwards shall be considered for FY 2025-26 and may not help in saving tax liability of FY 2024-25.

Conclusion:

The date is of paramount importance under legal statutes, and any actions undertaken after this specified date may lead to penalties or the forfeiture of benefits. Consequently, taxpayers must complete a range of necessary actions prior to March 31, 2025, in order to secure deductions and avoid penalties.

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