The Goods and Services Tax Network (GSTN) has deferred the planned locking of Table 3.2 in Form GSTR-3B, a move that would have restricted the ability of taxpayers to edit pre-filled data on inter-state supplies to unregistered persons and composition dealers. Originally scheduled to take effect from the April 2025 tax cycle, the change has been delayed following strong feedback from businesses. This decision offers critical relief for sectors heavily reliant on business-to-consumer (B2C) transactions. While the deferment is welcomed, it also highlights persistent policy volatility in India's indirect tax framework.
GSTN Halts Auto-Lock Function in GSTR-3B for Now
The Goods and Services Tax Network, the technology arm of India’s GST framework, announced on Friday that it would postpone the implementation of its earlier directive to lock Table 3.2 in GSTR-3B, the monthly tax payment form. Initially, the system was to restrict editing of this section beginning with the April 2025 tax period.
Table 3.2 captures inter-state supplies made to unregistered individuals, composition dealers, and entities with Unique Identification Numbers (UINs). This data is auto-populated from the supplier’s GSTR-1, GSTR-1A, and Invoice Furnishing Facility (IFF) submissions.
In an official advisory, GSTN stated that the decision to keep this table editable was taken “in the interest of taxpayer convenience and to facilitate smooth filing,” citing numerous taxpayer grievances and ongoing consultations.
Why the Change Matters: Impact on Business Compliance
Tax professionals and businesses had raised serious concerns over the proposed auto-locking mechanism. Many feared that system-generated values might not always align with their internal accounting records, especially in sectors with a high volume of B2C transactions.
Sandeep Sehgal, Partner-Tax at AKM Global, described the deferral as a "transitory relief" for businesses in segments like retail, fast-moving consumer goods (FMCG), hospitality, and e-commerce. These sectors often report large volumes of inter-state sales to unregistered buyers, where even small discrepancies between system-generated and internal records can complicate compliance.
According to Sehgal, “Maintaining flexibility in editing Table 3.2 is crucial. It ensures that taxpayers can match disclosures with actual transactional data, reducing the risk of errors and tax notices.”
Policy Whiplash: The Cost of Last-Minute Changes
While the deferment has been welcomed as a pragmatic response, it also reveals a deeper issue—policy inconsistency. Rajat Mohan, Senior Partner at AMRG & Associates, criticized the last-minute reversal as indicative of inadequate foresight.
“When enterprises have already integrated changes into their enterprise resource planning (ERP) systems and compliance protocols, an abrupt reversal imposes an operational burden,” Mohan explained. “It’s not just about data entry; it's about systemic reconfiguration, cross-departmental alignment, and workforce retraining.”
This inconsistency, he noted, undermines business confidence and strains compliance teams that must continuously adapt to an evolving regulatory landscape without adequate lead time.
Technology and Policy Need Better Synchronization
The issue underscores a larger challenge in India's GST framework: the alignment between technological automation and ground-level business realities. While GSTN aims to simplify compliance through digitization and pre-filled returns, a one-size-fits-all approach may not account for the operational nuances across industries.
The auto-population of Table 3.2, though designed for ease, assumes uniformity in taxpayer data quality and reporting practices—an assumption that does not hold true for large, diverse sectors with varying invoice structures and sales footprints.
Looking Ahead: A Call for Stakeholder-Centric Governance
The decision to postpone the locking of Table 3.2 is a step in the right direction, but it also serves as a reminder that policy formulation must be informed by stakeholder engagement and real-world testing. While digitization and automation are vital to modernizing India's tax architecture, they must be implemented with adequate consultation, predictability, and transitional support.
Until then, businesses and tax professionals remain at the mercy of policy volatility—forced to adapt on the fly in a system where clarity often arrives only after confusion.
Conclusion
GSTN's temporary rollback on locking Table 3.2 of GSTR-3B offers momentary respite, particularly for sectors with high B2C exposure. However, the abruptness of the policy shift highlights a need for more deliberate and consultative regulatory planning. As India continues to refine its indirect tax regime, balancing automation with flexibility, and stability with innovation, will be critical in earning taxpayer trust and promoting long-term compliance.
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