[Opinion] Your GSTR-1 Filing Could Be Blocked Starting September 1st

Prateek Mitruka – [2024] 165 taxmann.com 781 (Article)

Starting September 1, 2024, a critical rule under the GST regime will be strictly enforced, potentially blocking taxpayers from filing their GSTR-1 and using the Invoice Furnishing Facility (IFF) if they have not updated their bank account details on the GST portal. This article provides an exhaustive overview of this impending enforcement, explains the severe implications of non-compliance, and guides you step-by-step through the process of updating your bank account details to ensure continuous compliance.

1. Rule 10A. Furnishing of Bank Account Details

After a certificate of registration in FORM GST REG-06 has been made available on the common portal and a Goods and Services Tax Identification Number has been assigned, the registered person, except those who have been granted registration under rule 12 or, as the case may be rule 16, shall within a period of thirty days from the date of grant of registration, or before furnishing the details of outward supplies of goods or services or both under section 37 in FORM GSTR-1 or using invoice furnishing facility, whichever is earlier, furnish information with respect to details of bank account on the common portal.

2. Understanding the Basis of the Enforcement: Rule 10A of the CGST Rules

Rule 10A of the Central Goods and Services Tax (CGST) Rules, 2017, introduced via Notification No. 31/2019 dated June 28, 2019, mandates that every taxpayer must furnish the details of a valid bank account within 30 days from the date of grant of GST registration or must be done before the taxpayer furnish details of their outward supplies in FORM GSTR-1 or use the Invoice Furnishing Facility (IFF)—whichever occurs earlier.
This rule was implemented to ensure that the GST authorities have accurate and up-to-date information about the taxpayer’s bank account, which is crucial for various purposes, including processing refunds and monitoring financial transactions related to GST.

3. Recap of Previous Communications

Over the years, GST authorities have issued multiple communications, reminding taxpayers to furnish valid bank account details in their GST registration. Despite these reminders, a significant number of taxpayers have either overlooked or delayed this essential step. The upcoming enforcement is the government’s attempt to ensure full compliance with Rule 10A, underscoring the critical nature of this requirement.

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