ITC-04 job work sheet for CA firms: which clients file April–September 2026 by 25 October, and which challans are past the one-year limit
What you get: a ready-to-copy Google Sheet layout in two tabs: a clients tab that decides, per client, whether ITC-04 for April–September 2026 is due on 25 October 2026 or only annually, and a challans tab that ages every job-work challan against the one-year and three-year limits so nothing turns into a taxable "deemed supply" unnoticed. Plus a weekend plan and three client messages. Free, no sign-up.
Short answer (checked 21 Oct 2026): under rule 45(3) of the CGST Rules, a principal whose aggregate turnover in the preceding financial year exceeded ₹5 crore files Form GST ITC-04 half-yearly, by the 25th of the month after the period. For April–September 2026 that is Sunday 25 October 2026. Everyone else files once for the financial year (for FY 2026-27, by 25 April 2027). Sources: CBIC's text of rule 45 (as substituted by Notification 35/2021-CT, from 1 October 2021), section 143 of the CGST Act, and the GST portal's ITC-04 user manual. We found no extension notified as of 21 Oct 2026; the Commissioner can extend by notification, so check gst.gov.in before you act. This is a starting point, not tax advice.
Why it is easy to miss
ITC-04 carries no tax payment, so it does not show up in the GSTR-3B rhythm. It lands on a Sunday, three days after the quarterly GSTR-3B dates, and the client usually has the challan data while you have the portal login. Plan to file by Friday 23 October.
Tab 1 "clients": one row per client that sends goods for job work
| Column | What goes in it |
|---|---|
| A Client | Name |
| B GSTIN(s) | Every registration on the PAN that sends goods out |
| C Aggregate turnover FY 2025-26 (₹) | PAN-wide aggregate turnover as defined in section 2(6), not one GSTIN's sales |
| D Frequency | Formula below |
| E Due | Formula below |
| F Challan data received | Date the client sent the register / Excel |
| G Challans to report | Count for the period (over 500: use the portal's offline tool) |
| H Filed on | Date, with ARN in a note |
| I Status | Formula below |
D2: =IF(C2>50000000,"Half-yearly","Annual") E2: =IF(D2="Half-yearly",DATE(2026,10,25),DATE(2027,4,25)) I2: =IF(H2<>"","Filed",IF(D2="Annual","Not due now",IF(F2="","Chase client for challans",IF(E2-TODAY()<=2,"File today","Prepare"))))
Rows with "Chase client for challans" are your list for tomorrow morning.
Tab 2 "challans": one row per challan sent out
| Column | What goes in it |
|---|---|
| A Client | Same name as tab 1 |
| B Challan no. / date | Date in column C |
| C Sent on | Date goods left (or reached the job worker if sent directly from the supplier) |
| D Type | Input / Capital goods / Mould-die-jig-fixture-tool |
| E Job worker GSTIN or state | Registered or unregistered |
| F Qty sent | With unit |
| G Qty back / supplied from job worker | Total so far |
| H Loss / waste | As declared |
| I ITC-04 table | 4 sent · 5A back from same worker · 5B back from another worker · 5C supplied from worker's premises |
| J Limit date | Formula below |
| K Flag | Formula below |
J2: =IF(D2="Input",EDATE(C2,12),IF(D2="Capital goods",EDATE(C2,36),"")) K2: =IF(F2-G2-H2<=0,"Closed",IF(J2="","Open, no time limit",IF(J2<TODAY(),"Past limit: deemed supply, invoice + GSTR-1",IF(J2-TODAY()<=60,"Due back in "&(J2-TODAY())&" days","Open"))))
Why the flag matters: section 143(3) and (4) treat inputs not back (or supplied from the job worker) within one year, and capital goods within three years, as supplied by the principal on the day they were sent out; rule 45(4) says that supply goes in GSTR-1 with tax and interest. Moulds and dies, jigs and fixtures, and tools have no such limit. The Commissioner can extend the limits by up to one and two years on sufficient cause. Any challan showing "Past limit" is a conversation with the client before you file, not after.
Weekend plan
| When | What |
|---|---|
| Wed 21–Thu 22 Oct | Fill tab 1 turnover; send message 1 to every half-yearly client. |
| Thu 22–Fri 23 Oct | Load challans into tab 2, match qty sent vs back, resolve any "Past limit" rows, then prepare ITC-04 (online, or the offline tool for 500+ challans) and file with DSC or EVC. |
| Sat 24–Sun 25 Oct | Only late data. Annual filers: tell them the next date is 25 April 2027 and start the register now. |
Three client messages
1. Data request: "Your ITC-04 for April–September 2026 is due 25 October (a Sunday). Please send by Thursday the list of job-work challans sent out and goods received back in that period, with job worker GSTIN, quantity and any loss or waste."
2. Past-limit challan: "Challan [no.] dated [date] for [goods] has not come back within one year. Under the GST job work rules it is treated as a supply on the day it was sent, so an invoice with tax and interest is needed. Can you confirm whether it was returned or supplied from the job worker's premises?"
3. Annual filer: "Your turnover last year was within ₹5 crore, so ITC-04 is annual: FY 2026-27 is due 25 April 2027. Keeping the challan register monthly will make that a 20-minute job."
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