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ITC-04: The Specified Period and the ₹5 Crore Split

ITC-04 is the least-loved return in GST and the one with the highest stakes attached to it. It is the intimation that section 143 requires — and section 143 is the only reason the...

Vikas Sharma Tax & Compliance Expert
7 min read 11 views Updated Sep 16, 2026 Expert Reviewed Medium Complexity
ITC-04: The Specified Period and the ₹5 Crore Split
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Last updated: September 2026Verified against: Government sources
Quick Answer

ITC-04 is the least-loved return in GST and the one with the highest stakes attached to it. It is the intimation that section 143 requires — and section 143 is the only reason the goods left without tax.

ITC-04 is the least-loved return in GST and the one with the highest stakes attached to it. It is the intimation that section 143 requires — and section 143 is the only reason the goods left without tax.

The two frequencies

Principal's aggregate turnover in the preceding FYSpecified periodDue
More than ₹5 croreSix consecutive months commencing 1 April and 1 October25 October and 25 April
₹5 crore or lessA financial year25 April

Rule 45(3) in terms: the details "shall be included in FORM GST ITC-04 furnished for that period on or before the twenty-fifth day of the month succeeding the said period or within such further period as may be extended by the Commissioner by a notification in this behalf" — with any extension notified by a State or UT Commissioner deemed to be notified by the Commissioner.

The Explanation defines the specified period:

"(a) the period of six consecutive months commencing on the 1st day of April and the 1st day of October in respect of a principal whose aggregate turnover during the immediately preceding financial year exceeds five crore rupees; and (b) a financial year in any other case."

Note the test year. It is the immediately preceding financial year's turnover, so a principal that crosses ₹5 crore in FY 2025-26 moves to half-yearly filing for FY 2026-27, not mid-year.

What the form reports

The Handbook lists the four movements to be furnished by the principal:

  • (i) Goods dispatched to a job worker;
  • (ii) Goods received from a job worker;
  • (iii) Goods sent from one job worker to another; and
  • (iv) Goods directly supplied from the premises of the job worker.

Rule 45(3) as it now stands speaks of challans for goods "dispatched to a job worker or received from a job worker" — the words "or sent from one job worker to another" having been omitted by Notification No. 74/2018-Central Tax dated 31.12.2018, and "during a quarter" replaced by "during a specified period" by Notification No. 35/2021-CT.

The details are of challans, and the challan trail is the substance of the return. A principal that cannot produce a challan-level record cannot file ITC-04 correctly. The delivery challan →

Why it matters more than a return usually does

Section 143(1) permits a principal to send goods without payment of tax "under intimation and subject to such conditions as may be prescribed".

ITC-04 is that intimation. The Handbook: "The principal is required to file Form GST ITC-04… The said form will serve as intimation as envisaged under section 143 of the CGST Act, 2017."

So there is no separate intimation letter to the officer. But the corollary is uncomfortable: a principal who has never filed ITC-04 has never given the intimation on which the tax-free movement rests.

In practice, most disputes are not framed that way — the department is more likely to test the one-year and three-year returns, since that is where the tax lies. But the return is the primary record from which those periods are reconstructed, which is the practical reason to keep it accurate. Time limits and deemed supply →

The history, and why old periods look odd

Two waivers explain gaps in older records:

July 2017 to March 2019 — waived. "this requirement of filing Form GST ITC-04 has been withdrawn vide Notification 38/2019 Central Tax dated August 31, 2019, for the period July 2017 to March 2019."

April 2019 to June 2019 — one consolidated filing. "At the same time, the Form GST ITC-04 for the period April 2019 to June 2019 shall be filed with document-wise details of opening balance of goods available with the job worker."

That June 2019 return was therefore a reset point — it captured, document by document, everything then lying with job workers, and every later filing runs from it.

And the frequency changed on 01.10.2021. Before Notification No. 35/2021-CT, ITC-04 was quarterly for everyone, due within 25 days of the quarter. The ₹5 crore split replaced it.

The reporting that sits alongside

GSTR-1. "Details of delivery challan generated by the principal for the job work are also required to be furnished in Form GSTR-1 (Return of details of outward supplies of goods or services)."

And GSTR-1 again for a failure. Under rule 45(4), where inputs or capital goods are not returned within the section 143 time limit, the deemed supply "shall be declared in FORM GSTR-1 and the principal shall be liable to pay the tax along with applicable interest."

So GSTR-1 carries both the ordinary challan disclosure and the failure. ITC-04 carries the movement history that makes the two reconcilable.

A practical filing discipline

Age by original despatch date, not by challan date. The one-year and three-year clocks run from the first despatch and do not restart between job workers, so a register keyed to the latest movement will report everything as current.

Reconcile ITC-04 against the challan register and against GSTR-1 each period. The three should agree on quantity and value; a difference is either an unrecorded return or an unreported despatch.

Carry forward the closing balance. ITC-04 is cumulative in effect — goods dispatched in one period and returned in another appear in two returns, and the balance lying with each job worker at period end is what the next period opens with.

Watch the turnover test each April. Crossing ₹5 crore changes the frequency for the whole of the following year, and the first half-yearly return falls due on 25 October.

Key takeaways

  • Rule 45(3) — ITC-04 within 25 days of the end of the specified period.
  • Specified period: half-yearly (April–September, October–March) if preceding-year turnover exceeds ₹5 crore; annual otherwise — Notification No. 35/2021-CT w.e.f. 01.10.2021.
  • The test is the immediately preceding financial year's aggregate turnover.
  • ITC-04 reports goods dispatched to, received from, sent between job workers, and supplied directly from a job worker's premises.
  • ITC-04 serves as the section 143 intimation — the basis on which the movement is tax-free.
  • July 2017 to March 2019 was waived (Notification No. 38/2019-CT); April–June 2019 was filed with opening balances.
  • Challans are also reported in GSTR-1, as is the deemed supply under rule 45(4).
  • Age consignments by original despatch date and reconcile ITC-04 to the challan register every period.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on section 143 of the CGST Act, 2017, rule 45 of the CGST Rules, 2017 and Notification Nos. 51/2017, 74/2018, 38/2019 and 35/2021-Central Tax, as reproduced in the ICAI Handbook on Job Work under GST (4th edition, June 2026).

Key Facts About ITC

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

How often must ITC-04 be filed?

Half-yearly, for periods commencing 1 April and 1 October, where the principal's aggregate turnover in the preceding financial year exceeds ₹5 crore; annually in every other case.

When is ITC-04 due?

On or before the twenty-fifth day of the month succeeding the specified period — so 25 October and 25 April for half-yearly filers, and 25 April for annual filers.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

ITC: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

Related Services & Guides

Frequently Asked Questions
How often must ITC-04 be filed?
Half-yearly, for periods commencing 1 April and 1 October, where the principal's aggregate turnover in the preceding financial year exceeds ₹5 crore; annually in every other case.
When is ITC-04 due?
On or before the twenty-fifth day of the month succeeding the specified period — so 25 October and 25 April for half-yearly filers, and 25 April for annual filers.
What does ITC-04 report?
Details of challans for goods dispatched to a job worker, received from a job worker, sent from one job worker to another, and supplied directly from the job worker's premises.
Is a separate intimation to the department needed under section 143?
No. The Handbook confirms that Form GST ITC-04 serves as the intimation envisaged under section 143.
Was ITC-04 always required?
No. Filing was withdrawn for the period July 2017 to March 2019 by Notification No. 38/2019-Central Tax, and the April to June 2019 return was filed with document-wise opening balances.
Are job work challans reported anywhere else?
Yes — details of delivery challans generated by the principal are furnished in GSTR-1, where a deemed supply is also declared under rule 45(4).

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Vikas Sharma VERIFIED EXPERT
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Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.
Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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