This filing season carries a distinction that will not repeat. The Income-tax Act, 2025 came into force on 1 April 2026, but the return being filed now relates to income earned in FY 2025-26 — a period beginning before that date. Assessment Year 2026-27 is therefore governed entirely by the Income-tax Act, 1961: the forms, the sections, the late fee under Section 234F, and any defective-return notice under Section 139(9).

In practical terms, this is the last regular filing season under the 1961 framework. Returns for income earned from April 2026 onwards fall under the new Act and are not due until 2027.

Due dates are no longer a single date

The Finance Act, 2026 amended Section 139(1) to give non-audit taxpayers filing ITR-3 and ITR-4 a due date of 31 August, in place of the common 31 July. This is a permanent statutory change effective from AY 2026-27 — not the kind of last-minute extension the profession has grown used to waiting for.

• 31 July 2026 — ITR-1 and ITR-2 (salary, house property, capital gains, other sources)
• 31 August 2026 — ITR-3 and ITR-4 where the taxpayer is not subject to tax audit
• 31 October 2026 — audit cases, with the audit report due one month earlier

The revised return window under Section 139(5) closes on 31 March 2027.

Forms notified early

The CBDT notified ITR-1 to ITR-7 on 30 March 2026 through the Income-tax (Sixth Amendment) Rules, 2026 — considerably earlier than the late-April notification of the previous year. The filing window has been open since the start of the season, which is worth using: early filing reduces exposure to portal congestion and speeds up refunds.

Changes worth noting before you file

• Two house properties in ITR-1 and ITR-4. Eligibility has been widened; taxpayers previously pushed into ITR-2 for a second property may now file the simpler form.
• Schedule AL threshold raised. Assets and liabilities reporting now applies where total income exceeds ₹1 crore.
• Section 80G donations. The bank IFSC code and transaction reference number must now be reported for the deduction claim.
• Capital gains. The pre- and post-23 July 2024 rate split has been removed for AY 2026-27. Long-term capital gains disclosure has been expanded, including grandfathering and indexation details and scrip-level reporting for equity.
• F&O and intraday. Separate reporting fields have been introduced, which makes the classification between business income and capital gains harder to leave ambiguous.

Where returns actually go wrong

Two failure modes account for most of the trouble we see. The first is form selection: a return filed on the wrong form is treated as defective under Section 139(9), attracting a notice and a refiling. A salaried individual with a consultancy stream or a trading account belongs in ITR-3, not ITR-1, however simple the salary looks. Partners and their firms file separately — ITR-3 and ITR-5 — and those two filings must agree with each other.

The second is AIS and TIS reconciliation. With expanded scrip-level and derivative reporting, prefilled data is now detailed enough that unexplained differences surface quickly. Reconciling the Annual Information Statement against books before filing — rather than after a notice arrives — remains the single highest-return hour in the process.

This article reflects the position as at the date of publication and is provided for general information only. It does not constitute professional advice. Specific advice should be obtained before acting on any part of it.

The Invoice Management System has been available on the GST portal since late 2024, and for most businesses it was quietly ignored. That is no longer an option. From 1 April 2026, IMS applies to all regular registered persons filing GSTR-3B; taxpayers under the composition scheme are outside it.

The shift matters because IMS now sits upstream of GSTR-2B. Records no longer flow automatically from the supplier's GSTR-1 into your credit statement. They land on your IMS dashboard first, and only what you accept — expressly or by default — becomes available credit.

How the flow now works

A supplier files GSTR-1, the IFF, or an amendment through GSTR-1A. Those records appear on the recipient's IMS dashboard, where three actions are available:

• Accept — the record flows into GSTR-2B as available ITC and auto-populates GSTR-3B.
• Reject — the record is excluded from GSTR-2B. The supplier is notified and can amend or cancel in GSTR-1.
• Pending — the record is held back from GSTR-2B and stays on the dashboard until actioned in a later period.

Taking no action results in deemed acceptance. For genuine invoices that is harmless. For a wrongly-issued or fraudulent invoice raised against your GSTIN, it is precisely the failure mode the system was designed to prevent — and inaction hands the credit straight into your return.

Constraints worth knowing before month-end

• There is no partial acceptance. An invoice is accepted or rejected in full. Accepting a wrong-value invoice intending to adjust later is not a workable plan.
• Actions lock once GSTR-3B is filed for that period. Anything missed moves to the next cycle.
• Sequence matters. Acting on an amendment before the original record, where the two fall in different return periods, is blocked by the portal — and reconciliation then fails silently.
• Credit notes now ask whether ITC needs reducing. Declare the exact amount availed and reverse only that; where the answer is partial or nil, remarks are mandatory.

What does not pass through IMS

Not every credit is routed through the dashboard, and assuming otherwise creates phantom differences during reconciliation. ISD distributions appear in GSTR-2B directly. Import of services flows straight through, as do inward supplies liable to reverse charge reported by the supplier. Bills of Entry for imports of goods, including from SEZs, have appeared on IMS since the October 2025 tax period.

A workable monthly routine

With the portal now applying hard blocks on credit claimed in excess of GSTR-2B, the reconciliation cannot be left to year-end. A short, disciplined cycle handles most of it:

• Scan the IMS dashboard around the middle of the month, before the 14th.
• Reject anything that does not correspond to a purchase you recognise — check the supplier's registration status where a record looks unfamiliar.
• Match GSTR-2B against the purchase register line by line, not in total.
• Recompute GSTR-2B if any action was taken late, then file GSTR-3B.

Businesses under QRMP can run the same rhythm fortnightly. The objective is unchanged from the pre-IMS era — credit that is genuine, matched and documented — but the point of control has moved earlier in the month.

This article reflects the position as at the date of publication and is provided for general information only. It does not constitute professional advice. Specific advice should be obtained before acting on any part of it.

The assurance obligation on BRSR Core has been phased in by market capitalisation, measured as at 31 March. The top 150 listed entities came into scope for FY 2023-24, the top 250 for FY 2024-25, the top 500 for FY 2025-26, and the top 1,000 for FY 2026-27. The framework sits under Regulation 34(2)(f) of the LODR Regulations.

For an entity in the top 500 band, the disclosures as at 31 March 2026 are already inside the verification net. This is a present obligation, not a horizon.

What the easing did and did not do

SEBI spent much of 2024 and 2025 moderating the harder edges of the framework. The terminology moved to “assessment or assurance”. Value chain ESG disclosure was changed from comply-or-explain to voluntary by the circular of 28 March 2025, and mandatory value chain assurance was deferred.

None of that touches the Core. The nine BRSR Core attributes — spanning greenhouse gas emissions, water, waste, energy, gender diversity, wages, inclusive development, fairness in engaging with customers, and openness of business — remain subject to independent verification on the phased schedule. The Industry Standards on BRSR Core reporting, developed by the Industry Standards Forum and notified in December 2024, standardised the definitions, which in practice raises rather than lowers the evidential bar.

Where readiness usually fails

The gaps we encounter are consistent, and none of them are technical accounting problems:

• No named owner for a KPI. The classic discovery, three weeks before fieldwork, is that nobody actually owns the water number.
• Manual collection with no audit trail. A figure assembled from plant emails cannot be re-performed.
• Undocumented emission factors. The source and vintage of each factor must be evidenced, and the same rate used for the current and comparative year.
• Inconsistent output measures. Intensity ratios need a defensible denominator — for manufacturing entities, total production.
• No internal control layer. Data ownership and a sign-off ladder should exist before the assurance provider arrives, not in response to their queries.

Practical steps for the coming cycle

• Confirm your cohort against 31 March market capitalisation, and monitor rank if you sit near a band boundary.
• Assign a named owner and a documented methodology to each Core attribute.
• Freeze emission factors and output measures, and record the basis in writing.
• Run an internal dry run on the data pipeline — effectively an internal audit of the ESG numbers — well ahead of the engagement.
• Brief the audit committee on provider independence and on its own role in the integrity of the filed BRSR Core.

Entities in the top 1,000 band come into scope for FY 2026-27. The year in hand is the one in which the plumbing gets built quietly, or does not.

This article reflects the position as at the date of publication and is provided for general information only. SEBI’s requirements continue to evolve; current obligations should be confirmed against the applicable circulars. This does not constitute professional advice.