Sections extracted
- Section 47
- Section 168
- Section 44
- Section 35
GST circular working note
Circular 246/03/2025-GST: Clarification on applicability of late fee for delay in furnishing of FORM GSTR-9C
Source-led decode of CBIC Circular 246/03/2025-GST with the actual provisions, rules, forms and official PDF trail.
Reviewed by CA Nikhil Gupta · Updated 5 October 2026
Filing identity
Circular number
246/03/2025-GST
Date
2025-01-30
CBIC record
1003263
PDF source
official text PDF; 4 page(s)
Form in 2 minutes
Circular 246/03/2025-GST deals with clarification on applicability of late fee for delay in furnishing of FORM GSTR-9C. Read it as a rate, classification and taxability mapping: identify the supply, supplier, recipient, tariff or service description, notification entry and event date before applying the circular. The circular is binding administrative clarification under the GST framework only to the extent of the issue it answers; the Act, Rules, notifications and event-date version still control the final legal result.
Working point: On the issue of clarification on applicability of late fee for delay in furnishing of FORM GSTR-9C, a practitioner should match the product or service facts to the circular's described entry instead of extending the answer to nearby supplies by label alone.
Bare law, rules and notifications
Rules extracted
- Rule 80
Forms extracted
No GST form was expressly extracted from Circular 246/03/2025-GST.
Notifications and linked circulars
- Notification No. 08/2025-Central Tax
The source map above is limited to citations actually extracted from the official Circular 246/03/2025-GST PDF. Where the transaction also touches another charging section, exemption entry, return rule or limitation provision, document that separate source before filing or advising.
Paragraph-wise decode
| Para | Issue dealt with in the circular |
|---|---|
| 2 | In order to ensure uniformity in the implementation of the provisions of law across the field formations, the Board, in exercise of its powers conferred by sub-section (1) of section 168 of the CGST Act, hereby clarifies the issues as below. |
| 3 | Prior to 01.08.2021, sub-section (2) of section 44 of CGST Act provided that a registered person who is required to get his accounts audited in accordance with the provisions of sub-section (5) of section 35 of the CGST Act shall furnish the annual return under sub-section (1) of the said section along with a copy of the audited annual accounts and a reconciliation statement. From 01.08.2021 onwards, with the omission of Page... |
| 3.1 | Therefore, on a combined reading of section 44 of CGST Act with rule 80 of the CGST Rules, it can be concluded that both pre and post amendment, the provisions mandated that registered persons required to furnish an annual return in FORM GSTR-9 for a financial year shall also furnish along with it, a duly certified or self-certified reconciliation statement in FORM GSTR-9C, which reconciles the value of supplies declared in... |
| 3.2 | Sub-section (2) of section 47 of the CGST Act provides for a levy of a late fee for failure to furnish the return under section 44 of the CGST Act by its due date, which is to be computed at the specified rate, for each day for which such failure continues, subject to a maximum amount. As per the discussions above, in cases where reconciliation statement in FORM GSTR-9C is not required to be furnished, annual return under... |
| 3.3 | In view of the above, it is clarified that late fee under sub-section (2) of section 47 of the CGST Act, is leviable for the delay in furnishing of complete annual return under section |
Use these paragraph cues to locate the operative part quickly, then read the full official PDF for conditions, exceptions, examples, effective dates and past-period regularisation language.
Workflow
- Identify issue.
Record the taxpayer, supply, return period, order or refund event covered by Circular 246/03/2025-GST. - Map source.
Open the circular PDF with the Act, Rule and notification entries listed above. - Compile proof.
Contract, invoice description, product literature, HSN/SAC support, rate notification, exemption condition and tax-position memo. - Close filing.
Use the portal or officer channel that matches the event date and keep the acknowledgement with the source PDF.
Forms and downloadable source
Circular 246/03/2025-GST does not prescribe a separate static form PDF in its extracted source text. The operative document for this page is the circular PDF and the applicable Act, Rule, notification or portal process.
Do not use a form title by memory alone. Confirm the live portal, the rule that prescribes the form, historical return period and any officer instruction before upload or reply.
Highlighted advisory points
Scope
Circular 246/03/2025-GST should be confined to clarification on applicability of late fee for delay in furnishing of FORM GSTR-9C; nearby issues require their own source check.
Evidence
Keep the official PDF, transaction documents and portal record together so a reviewer can reproduce the conclusion.
Version
For historical periods, use the law and portal version applicable to the event, not merely the current screen label.
Exam and advisory case study
For exams and opinions, write the classification path: facts, statutory entry, notification condition, circular clarification, past-period treatment and practical billing result. For Circular 246/03/2025-GST, a complete answer names the issue, lists the controlling provisions extracted above, applies the circular's operative answer, and then states what the taxpayer or officer must do in the return, refund, appeal, billing or record file.
Finin2min summary and Q&A
Summary: Circular 246/03/2025-GST is a source-specific GST clarification on clarification on applicability of late fee for delay in furnishing of FORM GSTR-9C. Use the exact official PDF, not a generic circular checklist, and preserve the law/rule/notification map with the working file.
Is the circular itself the full law?
No. It clarifies administration under GST. The Act, Rules, notifications, court orders and facts of the transaction remain necessary.
When is a form PDF needed?
Only when the circular or linked rule actually points to a prescribed form. If the page lists forms, use the form compendium and the current GST portal version.
Can this be applied to another tax period?
Only after checking the effective date, amendment history and any past-period regularisation language in the official circular and related notification.
Primary official sources
CBIC circular metadata | Official CBIC PDF viewer | CBIC circular list | GST Council circulars
This Finin2min page is an educational working note. Official legislation, Gazette instruments, circulars, portal rules, court decisions and the facts of the matter prevail. Obtain professional advice for a live filing, refund, appeal or dispute.