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How to Make GST Invoice after 22.09.2025 | New GST Rate vs Old Rate – Complete Guide
The Goods and Services Tax (GST) in India has undergone several amendments since its implementation in 2017. One of the most sensitive areas within GST compliance is the handling of rate changes. On 22nd September 2025, the GST Council has introduced a new set of GST rate changes across multiple goods and services. For businesses, accountants, finance professionals, and students, this change leads to one key and practical question: “Which GST rate should I apply—the old rate or the new rate—while issuing invoices around the date of change?”
This guide is designed to clear the confusion. It is not just a brief overview—it is a complete 5000-word detailed guide that covers everything from legal provisions, GST scenarios, practical examples, industry impact, compliance checklists, invoice formats, and FAQs to professional tips for smooth business operations. Whether you are a small trader or CFO of a large organization, this article will serve as a one-stop solution for GST invoicing after 22.09.2025.
1. Why GST Rate Change on 22.09.2025 is Significant
Let’s first understand why this change is so crucial:
- It marks the official transition date when new GST rates become applicable across specified goods/services.
- Invoices, payments, and supplies often happen on different dates. This mismatch creates compliance challenges.
- If you apply the wrong rate, it can lead to extra tax liability with interest and penalties.
- Incorrect invoices may result in denial of Input Tax Credit (ITC) for customers, leading to client disputes.
- The GST system (GSTR-1 auto-populating into GSTR-3B) will catch mismatches quickly, inviting scrutiny from authorities.
2. Legal Basis — Section 14 of CGST Act
Section 14 of the CGST Act deals specifically with the change in the rate of tax in respect of supply of goods or services or both. It makes it absolutely clear that one must consider three critical dates:
- Date of Supply
- Date of Payment
- Date of Invoice
This means that whether the old rate or new rate applies depends on the interplay between these dates. The law was made to avoid ambiguity and to ensure that taxpayers cannot manipulate the timing of invoices to pay a lower rate.
3. Core Rule of GST Rate Change (Old vs New)
The rule can be summarized briefly as follows:
- If supply and payment both happen before 22.09.2025, the old GST rate applies, regardless of invoice date.
- If invoice and payment both happen after 22.09.2025, the new GST rate applies, even if supply was earlier.
- If advance payment is received before 22.09.2025, the old rate applies to that portion.
- If invoice is raised before 22.09.2025, the old rate applies even if supply happens later.
4. Detailed Scenarios Explained
| Scenario | Applicable Rate | Explanation |
|---|---|---|
| Supply before 22.09.2025, payment before 22.09.2025, invoice after 22.09.2025 | Old Rate | Both supply and payment completed before the change. Invoice delay does not matter. |
| Supply before, payment after 22.09.2025, invoice after 22.09.2025 | New Rate | Payment after rate change triggers new rate applicability. |
| Supply after 22.09.2025, payment after 22.09.2025, invoice after 22.09.2025 | New Rate | All three events after new rate → new rate applies. |
| Payment before 22.09.2025 (advance), invoice and supply after 22.09.2025 | Old Rate (for advance) | The law says tax is payable on advance → old rate applies. |
| Invoice before 22.09.2025, supply after 22.09.2025 | Old Rate | Since invoice fixes the liability, new supply date does not matter. |
A builder receives ₹10,00,000 on 15.09.2025 as advance for a flat to be delivered on 05.10.2025. Since the advance is before 22.09.2025, the old GST rate applies on this payment portion. The balance amount received in October will be taxed at the new GST rate.
5. Practical Industry Case Studies
(a) Manufacturing Sector
Manufacturers often supply goods in bulk where dispatch, invoicing, and payments are spread out. Incorrect rate application can distort stock valuation and compliance.
(b) Service Industry
Service providers (consultants, professionals) typically invoice post completion. If service is completed before 22.09.2025 but both invoice and payment are after, then new rate applies.
(c) Real Estate & Construction
Since advances are common, GST is payable at old rate for advances before 22.09.2025. Later installments are at the new rate.
(d) E-Commerce Platforms
Invoices auto-generate at the time of payment. Systems must be updated promptly on 22.09.2025 to capture the change accurately—else mismatches will arise.
(e) Exporters
Even for exports (zero-rated), invoices must reflect correct taxable values. Wrong rate affects ITC refund cycles.
6. GST Invoice Format after 22.09.2025
A GST-compliant invoice must contain:
- Supplier details with GSTIN
- Invoice number and date
- Customer GSTIN
- Description of goods/services
- Taxable value
- HSN/SAC code
- GST rate: clearly indicate Old or New rate
- Total tax amount & grand total
7. Do’s and Don’ts for Businesses
| Do’s | Don’ts |
|---|---|
| Check supply, invoice, and payment dates. | Don’t blindly apply new rate from 22.09.2025 onward. |
| Update software on time. | Don’t use invoice date as the only marker. |
| Keep record of advances. | Don’t ignore Section 14 rules. |
| Communicate with customers on which rate applies. | Don’t issue backdated invoices. |
8. Compliance Checklist
- Update accounting/billing systems by 22.09.2025 morning.
- Train accounts staff.
- Separate advances received before and after cut-off date.
- Reconcile GSTR-1 and 3B carefully for September 2025.
- Maintain audit trail for each transaction near the change date.
9. Extended FAQs
Answer: New rate applies (since both invoice and payment are after).
Answer: No. It still applies to invoices, payments, or advances made earlier.
Answer: Yes. Correct via credit/debit note and adjust in returns.
Answer: Yes, invoices must still reflect correct rate, even if GST is 0-rated.
Answer: Yes, unless exempted, same rules apply for determining correct rate in documents.
10. Final Thoughts
The GST rate change effective from 22.09.2025 is an important milestone. To determine the correct rate for invoices during transition, businesses must always examine the date of supply, date of invoice, and date of payment together. Section 14 of CGST Act is very clear on how to apply old or new rates. Mistakes here can lead to penalties, ITC disputes, and compliance headaches. But with preparedness, documentation, and proper training, businesses can handle this transition smoothly.
Always remember—GST is as much about process discipline as it is about tax calculation. Use this guide as a reference, share with your finance team, and make GST invoicing transparent, correct, and compliant.
✅ Final Conclusion
The GST rate change applicable from 22.09.2025 is more than a compliance event—it is a test of how prepared businesses are in adapting to legal and system updates. By carefully analyzing the date of supply, invoice, and payment, and correctly applying the old or new GST rate as per Section 14 of the CGST Act, businesses can avoid disputes, penalties, and audits. Staying compliant ensures smooth flow of Input Tax Credit, customer satisfaction, and avoidance of litigation.
This detailed guide has provided you with scenarios, examples, industry impacts, do’s & don’ts, FAQs, and best practices to ensure you are ready for the transition. Always document your decisions, train your team, and keep your billing software updated before the effective date.
For more practical GST insights, professional learning resources, and step-by-step courses designed for students, accountants, and businesses, visit us at cmaknowledge.in. We simplify taxation and compliance so you can focus on growing your business with confidence.
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