GSTR-3B ITC hard-locking: Table 4 is still editable

If you have been told your GSTR-3B ITC figure locks this month, check before you re-plan your close. The outward-liability tables are non-editable and have been for a year. Table 4 — the ITC block — is not, and no GSTN advisory has ever fixed a date for it. Here is what is actually frozen, what is not, and the deadline that genuinely constrains your credit.

Do this first

Before you change anything in your month-end calendar, open a live GSTR-3B for an open period and try to type over the auto-populated ITC figure in Table 4(A)(5). It should accept the edit — no GSTN advisory has ever removed it. That thirty-second check settles it for your own GSTIN, and it will not match what a good deal of tax commentary has been telling you since the spring.

The reason to check rather than trust is that hard-locking is not law. It is portal configuration, announced by GSTN advisory and retunable without any public instrument. There is no Act provision, rule or notification that mandates it. That cuts both ways: a lock can arrive without a statutory amendment, and an announced lock can be withdrawn — which has already happened once on the liability side of this same return.

What is locked today, table by table

Three separate decisions are routinely merged into one story. They are not one story, and they carry three different dates.

The liability lock came in two waves — GSTN's advisory of 7 June 2025 for Tables 3.1 and 3.1.1, and a separate advisory of 5 December 2025 for Table 3.2. Table 3.2 did not lock in July 2025, and dating it there is one of the more common errors in circulation.

Table 4 is in a different position entirely. The only GSTN instrument that has ever addressed ITC locking is the advisory of 17 October 2024, which said the change "will be implemented from a later date" and that "a separate advisory would be issued after addressing all the issues related to IMS". That separate advisory has not issued. Twenty-one months on, the deferral stands.

Where the "July 2026" date came from

The date is not GSTN's. It appears in secondary tax media, generally self-hedged as "expected" or "targeted", and then loses the hedge as it is copied. The associated "phase one / phase two" vocabulary is media shorthand too; GSTN's own advisories say only "non-editable".

GSTN has in fact rebutted the drift directly. Its advisory of 8 October 2025 was headed to the effect that there is no change in the auto-population of ITC, and stated that the mechanism of auto-population remains unchanged. And there is a precedent for a lock date being pulled — though it is worth being precise about which limb it landed on. The 17 October 2024 advisory carried two limbs: it set the liability lock for the January 2025 tax period, and it said only that ITC locking would follow "from a later date". The advisory of 27 January 2025 withdrew the January date; the liability lock eventually arrived six months late, in July 2025. So the January 2025 date was never an ITC date — the ITC limb has carried no date at any point since October 2024. The precedent cuts two ways: a dated GSTN lock can slip by six months, and the undated one has not moved at all.

The practical instruction is narrow. Do not put an ITC-lock date in a board paper, a client advisory or a systems-change business case unless you can point at the GSTN advisory that carries it. As of today there is none.

The deadline that does bind you

Editability is not a defence, and this is the part the hard-locking story distracts from. Rule 88D compares the ITC you claim in GSTR-3B against the ITC available in your GSTR-2B whatever you type into Table 4. If the claim runs ahead beyond the portal's threshold, Form DRC-01C is generated automatically; you then pay with interest or reply in Part B within seven days, or you are barred from filing your next GSTR-1 under Rule 59(6).

A worked example. Take a manufacturer with 240 active vendors filing for the June 2026 period:

Because Table 4 is editable, this taxpayer can type Rs 84,20,000 and file. Nothing on the portal stops them. What the edit does not do is make the credit eligible: under Section 16(2)(aa), ITC can be claimed only if the invoice has been furnished by the supplier in GSTR-1 and communicated in GSTR-2B. The Rs 4,60,000 is not yet claimable — it lands in a later 2B once the vendors file. The Rs 55,000 duplicate is not claimable at all and should have been rejected in IMS rather than left to deemed acceptance.

Whether that Rs 5,15,000 gap fires a DRC-01C is genuinely unknowable in advance. Rule 88D fixes no figure — it delegates to "such amount and such percentage as may be recommended by the Council". The one figure on the record is a recommendation of the 50th GST Council on 11 July 2023: a difference of more than 20% as well as more than Rs 25 lakh, both limbs together. GSTN has never published the operative limit, describing it only as "a predefined limit" and "the configurable threshold". Any "Rs 1 lakh or 20%" figure you encounter is folklore — it traces to neither the Rule, the minutes nor GSTN.

So the honest management rule is not "stay under a number". It is: know your 2B-versus-3B gap before you file, and be able to name the invoices in it. A reconciled gap is safe at any threshold setting. An unexplained one is a coin toss.

What to have in place anyway

A Table 4 lock would remove the ability to paper over a gap in the return. Everything below is worth doing before that happens, and each item earns its keep today regardless:

• Claim from 2B, not from the purchase register. Section 16(2)(aa) makes 2B communication a precondition. If it is not in 2B this month, it is not this month's credit.
• Work IMS before the cut-off. Take no action on a record and it is deemed accepted into your 2B. Rejecting a duplicate takes a positive act; accepting one does not.
• Reconcile at invoice level, not at total level. A net gap of Rs 5,15,000 tells you nothing. The vendor names behind it are what you can act on — chase four suppliers, or explain four lines in a Part B reply.
• Route liability corrections through GSTR-1A. Tables 3.1, 3.1.1 and 3.2 are frozen by advisory, so that habit needs to exist now. One caveat on the liability side, stated plainly: GSTN currently publishes two accounts of it. The advisories of 7 June 2025 and 5 December 2025 say non-editable; the GSTR-3B FAQ and user manual on tutorial.gst.gov.in still describe auto-populated values as editable. Those help pages are demonstrably stale — they also still call Table 3.2 editable, which the December advisory refutes — so they do not unsettle the lock, but they do mean the advisories, not the FAQ, are the position to work from.
• Track the downstream clocks. Credit accepted today still reverses under Rule 37 if the supplier is not paid within 180 days of the invoice date, with interest, and is re-availed only on payment.

How Recoup fits

Recoup reconciles your Zoho Books ITC against your GSTR-2B continuously, so the gap between what your books say and what the portal will allow is visible before you file rather than after. It flags the exact invoices driving a gap, names the vendor who has not filed, separates benign timing differences from genuine excess, and tracks the Rule 37 180-day clock. None of that depends on whether Table 4 is editable — which is the point. The lock was never the deadline.

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