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India’s revised GST rates for most goods and services took effect on 22 September 2025. The rate on a transaction follows the time-of-supply and supply-date rules, not simply the date a business bought its stock. That means a compliant changeover must update prices, tax masters, inventory views, invoices, credit notes, input-tax-credit controls and e-invoice integrations together.
What changed on 22 September 2025
The general effective date
The Ministry of Finance FAQ dated 3 September 2025 says that, following the 56th GST Council meeting, changes in GST rates for services and goods other than the specified tobacco products would be effective from 22 September 2025. For most businesses, that date is the operational cutover: supplies made on or after it must be evaluated against the revised rate schedule and the applicable time-of-supply rule.
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The date is not a licence to apply one rate to every document created after midnight. A supply that occurred earlier can remain governed by the earlier treatment when the statutory conditions in Section 14 of the Central Goods and Services Tax Act are met. Invoice date, payment date and the actual supply date can change the result, so software needs transaction-level logic rather than a simple calendar switch.
Tobacco products were treated separately
The same Ministry FAQ excludes cigarettes, chewing tobacco products such as zarda, unmanufactured tobacco and beedi from the 22 September change. Their revised treatment was deferred until a later notification. A tax master should therefore keep these products on a separate effective-dated rule and should not assume that the general cutover applies to them.
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Which GST rate applies to stock and sales?
Purchase date does not decide the selling rate
The PIB FAQ of 21 September 2025 states: “GST is charged on the date of supply, not on the date of purchase.” Inventory bought under the earlier rate but supplied on or after 22 September must normally be billed at the rate applicable to that later supply. The tax on the purchase remains part of the historical purchase and input-credit record; it does not turn the later sale into an old-rate transaction.
This distinction matters for distributors, retailers and manufacturers with goods in warehouses or in the market. The PIB FAQ also says that stock already in the market can continue to be sold, provided billing reflects the new prices. Businesses do not have to write off usable stock merely because the rate changed, but they do need to calculate the tax on each post-cutover supply correctly.
Supplies before the cutover
When the supply predates 22 September, Section 14 time-of-supply provisions determine whether the earlier rate applies. The deciding facts can include when the invoice was issued and when payment was received. A document created after the cutover cannot, by itself, convert an earlier supply into a later one. Keep the evidence that establishes the supply date, invoice event and payment event together with the transaction.
Advances received around the date
An advance received before the change can preserve the earlier treatment when the conditions described in the Ministry FAQ are satisfied. Your accounting system should record the receipt date, the related order or supply, the tax rate used on the advance document and the date on which the final supply is completed. Do not force every advance into the rate active on the final invoice date without applying the time-of-supply rule.
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E-way bills already issued
E-way bills issued before the change remain valid for their full validity period, according to the PIB FAQ. A rate update therefore does not automatically require cancellation and re-issuance of an otherwise valid e-way bill. Check that the invoice and tax details associated with the movement reflect the rate that applies to the supply.
How the change affects prices and margins
Tax-inclusive prices
A rate change can alter a tax-inclusive selling price immediately. For a tax-exclusive price, the calculation is base price multiplied by the applicable rate. For a tax-inclusive price, separate the tax component from the displayed total before applying the new rate. Preserve the business decision about whether to pass the difference to the customer, hold a consumer-facing MRP where legally and commercially appropriate, or absorb the difference in margin.
Do not bury that decision in a one-time spreadsheet edit. Store a versioned price list with an effective-from date, the tax-exclusive price, the tax-inclusive display price and the approval or policy reference. A retailer may choose a different rounding or customer-price policy from a wholesaler, while both still need to report the legally correct tax.
Old purchase cost versus new tax payable
Inventory reporting should show at least four separate values: purchase cost, input tax credit, selling price and output tax payable. A lower selling tax rate does not automatically mean the purchase cost has fallen, and a higher output rate does not revalue goods already purchased. Keeping these columns separate prevents a rate change from being misread as a stock write-down or an unexplained margin movement.
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Open orders and quotations
Quotes, sales orders and contracts that straddle the cutover need a status-based rule. Reprice an open document when its supply, invoice and payment facts make the new rate applicable; retain the original version so the customer can see what changed. A posted invoice should not be rewritten merely to make its rate match a later master-data edit.
Input tax credit (ITC) after a rate change
Correctly charged pre-change input tax remains creditable, subject to the normal eligibility and documentation requirements. Keep the supplier invoice, receipt evidence and original tax amount even when the goods are sold after 22 September. Your reconciliation should be able to trace that credit from the purchase ledger to the relevant return period.
If a supply becomes exempt after the change, ITC linked to that supply may require reversal. The PIB FAQ and Ministry FAQ identify this consequence, but the amount and method depend on the applicable GST provisions and records. Flag newly exempted HSN or SAC mappings for an ITC review rather than automatically deleting historical credits.
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A rate cutover is safest when treated as a controlled release across point-of-sale, inventory, accounting, ERP and e-invoice systems. Use this sequence:
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- Build an effective-dated tax master. Add effective-from and effective-to dates to every GST rate and HSN/SAC mapping. Keep the prior version active for historical documents, returns, cancellations and audit queries.
- Map the legal facts. Capture supply date, invoice date, payment or advance date, document type and place of supply. Route invoices, debit notes, credit notes, returns and advances through the time-of-supply decision instead of selecting a rate from the document date alone.
- Version price lists. Store tax-exclusive and tax-inclusive prices separately, with rounding rules and an effective date. Reprice quotations and open orders only after checking their supply and payment status.
- Protect posted documents. Lock historical invoices and preserve the source rate, HSN/SAC, place-of-supply decision and user or process that selected it. Correct an error through the permitted credit-note, debit-note or cancellation workflow, not by editing the original record.
- Separate tax components in inventory. Retain the original purchase tax for ITC and margin analysis while calculating output tax at the rate applicable to the sale. Show stock supplied after the cutover as a distinct reconciliation population.
- Validate CGST, SGST and IGST. Recheck the customer’s registration state, place of supply and intra-state or inter-state determination. The rate master and tax-component split must be synchronized across every channel.
- Synchronize all endpoints. Push the same effective-dated master to POS terminals, mobile sales apps, warehouse systems, accounting ledgers, ERP instances and e-invoice API connectors. A correct central table is not enough if a disconnected till keeps an old rate.
- Reconcile the first transactions. Compare invoices, inventory issues, tax ledgers, e-way-bill data and e-invoice responses for the first post-cutover supplies. Investigate differences before the next return is prepared.
- Test exception documents. Run scenarios for pre-cutover advances, post-cutover delivery of old stock, returns, cancellations, credit notes, debit notes and supplies that become exempt. Confirm that each document retains the original rate where required.
- Retain an audit trail. Log who approved the new rate, when it became active, which records were recalculated and which were deliberately left unchanged. Export the log with the tax-master version used for a transaction.
E-invoicing requirements and rate-master readiness
New 40% rate in the production tax master
IRIS IRP release notes record that a new 40% GST rate was added to the Tax Rate Master in its production environment on 21 September 2025. If that rate applies to a classified supply in your business, your connector must accept it, map it to the correct HSN or SAC and produce the expected e-invoice payload. Test both successful generation and rejection handling before enabling it for live billing.
Thirty-day reporting window for larger taxpayers
The same IRIS IRP portal states that, effective 1 April 2025, taxpayers with aggregate annual turnover (AATO) of ₹10 crore or more must report e-invoices within 30 days from the invoice date. The rule covers invoices, credit notes and debit notes. An ERP queue that waits for month-end batching can therefore miss the reporting window; monitor the age of every unreported document and surface failures to an owner.
API and response controls
Store the request payload, acknowledgement number, acknowledgement date and error response for each submission. A rate-master update should not silently alter a previously generated invoice. If a document is rejected because of an HSN, rate or place-of-supply mismatch, correct the underlying transaction and follow the permitted cancellation or re-issuance process.
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The 55th GST Council release recommends a legal framework in which taxpayer actions in the Invoice Management System support GSTR-2B generation, credit-note ITC reversal and sequencing of GSTR-3B after GSTR-2B is available. The release also says that recommendations take legal effect through notifications or amendments. Treat the recommendation as an integration requirement to prepare for, and verify the current notification before putting a workflow into production.
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Practically, your system should match supplier invoices and credit notes, expose an accept, reject or amendment decision where the current IMS process requires it, and prevent a credit-note reversal from being lost between the purchase ledger and the return preparation screen. Keep the IMS event history with the invoice version used for reconciliation.
Controls and tests that catch expensive errors
Cutover test cases
- Goods purchased before 22 September and supplied afterward: output tax uses the applicable new rate while purchase ITC retains the original tax.
- Supply completed before 22 September with invoice or payment around the cutover: Section 14 logic determines the result and records the evidence.
- Advance received before the change and final supply afterward: the system applies the qualifying advance treatment and reconciles the balance.
- Stock already moving under a pre-change e-way bill: validity is preserved while invoice tax details remain correct.
- A product or service that becomes exempt: the ITC review queue identifies potentially reversible credit.
- Credit note against an old invoice: the document inherits the original transaction context rather than the current default rate.
- Inter-state and intra-state versions of the same sale: CGST/SGST versus IGST follows place of supply.
Reports management should review
- Stock supplied after 22 September, grouped by old purchase rate and new output rate.
- Open orders and quotations whose tax-inclusive customer price changed.
- Advances received before the cutover that remain unapplied or partially applied.
- Pre-change ITC carried into the current reconciliation and any newly exempt supply flagged for reversal.
- Invoices, credit notes and debit notes approaching the 30-day e-invoice limit for AATO-eligible taxpayers.
- Differences between POS, inventory, accounting, ERP and e-invoice tax masters.
How to evaluate GST-ready billing software
When selecting or upgrading a system, compare capabilities rather than the marketing label “GST ready.” Ask for a demonstration using your own cutover scenarios and insist that the vendor identify what is configurable, what is hard-coded and what is retained in the audit log.
| Capability | What to verify |
|---|---|
| Effective-dated tax masters | Separate old and new rates, HSN/SAC mappings, activation dates and rollback controls. |
| Time-of-supply handling | Rules for supply, invoice, payment and advance dates under Section 14. |
| Price and stock versioning | Tax-inclusive and tax-exclusive prices, open-order repricing and purchase-cost separation. |
| Document corrections | Credit notes, debit notes, returns, cancellations and historical-document protection. |
| ITC and reconciliation | Tracing pre-change credit, identifying exempt-supply reversals and matching supplier documents. |
| IMS/GSTR-2B workflow | Event history, credit-note sequencing and controls before GSTR-3B preparation. |
| E-invoice connectivity | Current IRP rate-master support, API acknowledgements, rejection queues and 30-day ageing alerts. |
| Multi-state and multi-entity control | Place-of-supply accuracy, separate registrations, shared masters and entity-level audit logs. |
What businesses should do now
First freeze and export the pre-change tax and price masters. Then create the 22 September effective-dated versions, map affected HSN and SAC codes, and test representative transactions in a non-production environment. After deployment, reconcile post-cutover sales and stock daily until the first return cycle is complete. Keep the Ministry of Finance FAQ, PIB FAQ, IRIS IRP release notes and the latest applicable notifications with the change record so an auditor can see why each rule and date was used.
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