Subject: Guidance Required on Reporting Missed FY 2024–25 B2B Supplies and E-Invoice Non-Issuance.

[vaibhav kumar]

Dear Sir/Madam,

We seek your professional guidance on a GST compliance matter, the details of which are outlined below.

We had B2B supplies during FY 2024–25 which were not reported in the relevant GSTR-1 and GSTR-3B for the respective periods. Further, e-invoices were not issued at the time of supply, and the 30-day time limit for e-invoice reporting has since expired.

We now intend to declare these transactions and pay the applicable GST along with interest in the current returns (December-2025 GSTR-3B and GSTR-1). Due to the above constraints, we are considering reporting these transactions as B2C instead of B2B. We also propose to disclose the same in GSTR-9 (Table 10) for FY 2024–25. As B2C Supply.

In this context, we request your advice on the following:

1. What is the correct and legally compliant method to disclose these missed FY 2024–25 supplies at this stage?
2. Considering that the e-invoice was not issued and the prescribed time limit has lapsed, is it permissible to report these B2B supplies as B2C in the December GSTR-1 and GSTR-3B, or would this be regarded as misreporting under GST law?
3. What would be the recommended and safest approach to regularize this matter and minimize exposure to penalties, interest, or future litigation?

We would appreciate your guidance on the appropriate course of action.

Thanking you.

[Ryan Vaz]

• Reporting B2B supplies as B2C is NOT legally permissible and would amount to misreporting / suppression under Section 122.

• E-invoice non-generation does NOT convert a B2B supply into B2C. Nature of supply depends on recipient’s GST registration status, not reporting convenience.

• GSTR-9 Table 10 cannot cure or regularise misclassification; it only reports amendments already made in returns.

• The safest approach is to declare the missed supplies as B2B, pay tax + interest, and proactively manage exposure through voluntary disclosure and documentation.

[Sooraj B]

1. The correct method for reporting the transaction would be to report it in Table 4B (add the taxable value and tax figures to the auto -populated figures) and Table 9 (only the tax under tax payable) of GSTR-9. The tax payable may be paid along with applicable interest through DRC-03 by selecting the reason as Annual Return.

2.The transaction is no longer reportable in the monthly returns as any transactions for FY 2425 are to be reported in the GST returns filed on or before 30th November 2025.

3.Reporting the transaction and paying the applicable tax along with interest will help to avoid penalty to a great extent. However penalty may still be issued for non-issuance of e-invoice (it may be noted that where a person required to issue e-invoice does not issue an e-invoice, the document issued by the person will not be considered as an invoice under the GST Law).

[Shilpi Jain]

Since you have not issued e-invoice you can issue that now with current date. This will also enable credit to your customer.

Interest liability exists though it all depends on how the departmetn is able to identify that the supply is of the past.

AI Summary

Missed B2B supplies must be declared as B2B, tax and interest paid, and voluntarily disclosed to reduce enforcement risk. Missed FY 2024-25 B2B supplies must be disclosed as B2B; reporting them as B2C is not permissible and may amount to misreporting. E invoice non issuance does not change supply character. The correct approach is to declare the transactions as B2B, pay outstanding tax with interest, and make a voluntary disclosure in the annual return and through the statutory payment process to mitigate enforcement risk, although penalties for non issuance of e invoices may still apply.