BCAS urges GSTR-3B deadline extension to avoid Diwali compliance crunch; check details

The Bombay Chartered Accountant Society (BCAS) has formally appealed to the Finance Minister to consider extending the statutory deadline for filing GSTR-3B returns for September 2025, citing the direct clash between the current due date and the Diwali festival period. The standard deadline, set for 20 October 2025, falls on Sunday, 19 October, and closely coincides with the main days of Diwali, when a majority of professionals, accountants, and company staff observe public holidays. This overlap, according to BCAS, significantly restricts the compliance window, raising concerns about the ability of businesses and practitioners to complete essential return finalisation tasks on time. The request for extension aims to provide administrative relief and uphold the integrity of return filings during this nationally significant festival period.

Preparation and submission of Form GSTR-3B involve several steps for taxpayers, including reconciliation, data entry, and review of Input Tax Credit (ITC) eligibility. For many filers, finalisation also depends on the timely generation of GSTR-2B after the 14th of each month, followed by arranging funds for tax payment. BCAS notes that the period from 19 October onwards is dedicated to Diwali, making the effective window for these compliance activities extremely narrow for many registered persons.

GSTR-3B is a simplified summary return required to be filed by regular and casual taxpayers for every tax period. Completing this return is crucial for reporting GST liabilities and settling dues. Any delay or inability to file due to holiday-related disruptions could potentially lead to penalties and non-adherence to the Central Goods and Services Tax (CGST) Act, which governs the compliance regime for GST in India.

The BCAS representation, dated 8 October 2025, emphasises that the timing of the statutory due date immediately after a public holiday creates logistical challenges for taxpayers and professionals alike. With 20 October marking both the due date and the start of a major festival cluster, the society argues that a short-term extension would ensure compliance is both complete and accurate. The request is positioned as a measure that supports the ease of doing business while maintaining the integrity of the tax system.

In its submission, BCAS states: “Therefore, as a significant step towards ease of doing business, it is earnestly requested that the due date for filing GSTR-3B of September 2025 be extended. Granting this essential administrative relief will enable registered persons and tax practitioners to complete the necessary compliance procedures following the conclusion of the festival period, ensuring accurate and complete return filing and promoting adherence to the provisions of the CGST Act without penalising taxpayers for unavoidable circumstances.”

The society further highlights that the compliance bottleneck is exacerbated by the requirement to complete all reconciliation and fund arrangements before the festival, given that public holidays on and after 19 October restrict access to personnel and support services. This, according to BCAS, makes it difficult for many taxpayers to fulfil statutory obligations within the prescribed timeframe.

BCAS also clarified the specifics of a Nil Return in Form GSTR-3B, which can only be filed when there are no outward or inward supplies or liabilities for a given tax period. For most regular businesses, achieving Nil Return status for September is unlikely, reinforcing the necessity for an operational compliance window that extends beyond the holiday period.