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GST Compliance – Communication Between Taxpayers (CBT)

A. The Law

Relevant Sections – CGST Act, 2017

  • Section 37 & 38: Furnishing details of outward and inward supplies.

  • Section 61: Scrutiny of returns – authorities can question mismatch of invoices.

  • Section 168: CBIC empowered to issue instructions for system-based compliance.

  • Section 122 & 125: Penalties for failure to furnish details or wrong declaration.

Relevant Rules – CGST Rules, 2017

  • Rule 59 & 60: Filing of GSTR-1 and GSTR-2B linked with counterparties’ data.

  • Rule 142: Communication of demand or payment through electronic modes.

  • System Functionality: Communication Between Taxpayers is a facilitative mechanism under GST Portal (not a statutory return), enabling taxpayers to communicate missing/mismatched invoice details.


B. How Do I – Step-wise Compliance Process

Step 1: Login

  • Visit gst.gov.in → Login with valid GSTIN credentials.

  • Navigate to Services > User Services > Communication Between Taxpayers.

Step 2: Functional Tabs

  • Inbox: Notifications/replies received from counterparties.

  • Compose (+): To send new notification to Supplier/Recipient.

  • Outbox: Notifications/replies sent.

  • Download CSV Template: To upload multiple documents at once.

Step 3: Send Notification

  1. Click + Compose.

  2. Select Notification To → Supplier / Recipient.

  3. Enter counterparty’s GSTIN (auto-populates Trade/Legal name).

  4. Enter Subject (max 50 chars).

  5. Choose Form Type (GSTR-1 or GSTR-3B), FY, Return Period.

  6. Add records (invoice/credit note/debit note).

    • Manually: Add one by one with Action Required (e.g., File Missing Document, Amendment Required, Wrongly Sent, Payment Made).

    • CSV Template: Download, fill details (max 50 documents per notification), upload.

  7. Add Remarks (max 200 chars).

  8. Attach supporting docs (max 4 files, PDF/JPEG, 5MB each).

  9. Click Send. System sends SMS & Email to counterparty.

Step 4: View Reply

  1. Go to Inbox → Notification & Reply Received.

  2. Select Supplier/Recipient tab.

  3. View details, download CSV/attachments if shared.

  4. Click Reply/Take Action.

  5. Provide response (e.g., Document Filed, Document Uploaded, Not Belonging to Me).

  6. Add remarks, upload attachments if needed.

  7. Click Send. Success message + SMS/Email sent.

Step 5: Upload Missing Document to GSTR-1 (Supplier only)

  • If recipient reports missing invoice:

    • Supplier can directly upload document to nearest open GSTR-1 period.

    • Three scenarios:

      1. Already filed → system says “Already Filed.”

      2. Saved but not filed → Overwrites saved draft.

      3. Not saved/ filed → Upload allowed.

  • Document moves to next available open return if earlier filed.


C. FAQs (15 Clarifications & Common Errors)

  1. Who can use CBT facility?
    All registered taxpayers except TDS, TCS & NRTP.

  2. Can I send notification to both suppliers & recipients?
    Yes, facility covers both directions.

  3. How many notifications can be sent per GSTIN?
    Max 100 per tax period (month/quarter).

  4. Do counterparties get alerts?
    Yes, via email, SMS, and dashboard alert.

  5. Can attachments be sent?
    Yes, up to 4 files (JPEG/PDF, 5 MB each) with notification/reply.

  6. Can missing documents be uploaded to GSTR-1?
    Yes, supplier can upload to nearest open GSTR-1 using CBT.

  7. What if I try uploading a document already filed?
    System blocks and shows “Already Filed”.

  8. Can CSV be used?
    Yes, up to 50 documents per CSV; more require separate notifications.

  9. What if ARN mismatch while responding?
    Error occurs; check GSTIN, document no. & date.

  10. Can notification subject exceed 50 chars?
    No, max 50 characters allowed.

  11. Can reasons be deselected once entered?
    No, must delete and re-enter.

  12. What if counterparty doesn’t respond?
    Reminder can be sent by recipient to supplier (not vice versa).

  13. Are actions item-specific or consolidated?
    Item-level wise – each invoice/note must be tagged with required action.

  14. What if more than 50 records?
    Split into multiple notifications.

  15. Is CBT legally binding like DRC notices?
    No, it is a facilitative tool for reconciliation, not statutory demand.


D. Fillable Checklist – Communication Between Taxpayers

Particulars Details / Action
GSTIN of Counterparty
Notification Type ☐ Supplier ☐ Recipient
Subject (≤50 chars)
Return Period & FY
Form Type ☐ GSTR-1 ☐ GSTR-3B
Action Required ☐ File Missing Doc ☐ Amendment ☐ Wrongly Sent ☐ Payment Made ☐ Payment Not Received ☐ Others
Remarks (≤200 chars)
Attachments (≤4 files, 5MB)
Sent Successfully? Yes / No
Reply Received? Yes / No
Uploaded to GSTR-1 (if applicable) Yes / No

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