ITC reporting in GSTR-9: GSTR-2A Reconciliation, Challenges & Clarifications

A user faces many issues relating to settlement, disclosure etc of Input Tax Credit (ITC) at the time of GSTR 9 Annual Return Filing. We provide you a comprehensive solution of all such queries, you have been witnessing so far..

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Credit appearing in the GSTR-2A exceeds amount availed in the GTR-3B. Is the difference required to be explained in GSTR-9?

Yes, the difference between auto populated ITC details of GSTR 2A and ITC details declared in GSTR-3B needs to be explained in Annual return. GTSR 9 will have an auto filled Table 8D reflecting the amount of difference. And the explanation of which is to be given under

  • Table 8E – For ITC available but not availed
  • Table 8F – For ITC available but ineligible

Hence, the difference between GSTR-2A and ITC as per GSTR-3B needs to be analysed in these two headings and to be reported in the Annual Return.

We missed out availment of input tax credits on few invoices last year. Whether credit of the same has to be taken in the Annual Return?

Any missed out credit of the last FY year has to be availed in the GSTR-3B of the month of September 2018. There is no provision for availment of credit in the Annual Return. The Annual return form provides for reporting of credits which have been availed in the GST returns filed for FY 2017-18. Hence, only those credits which have been availed in the same financial year should be considered as part of input tax credit. However, Sl.No.8 under Part III provides for disclosure of information w.r.t. credits pertaining to FY 2017-18 availed during the period April-September 2018, purely as a check with Form GSTR-2A credits and an informative requirement. Also, the details of credit so availed has to be reported in the Part V of the Table 13 for disclosure requirement.

What is the reason for declaring the taxes paid on import of goods and bifurcation of it between credits availed as well as not availed thereon?

Imagine a situation where a person makes import and further sell goods in market. But, somehow skips to record the complete transactions in books of accounts. How will the government trace such transaction??

The same is the reason behind bifurcating

  • Taxes Paid
  • Credits availed
  • Credits not availed

On import at the time of filing GSTR 9.

Since, the transaction have been missed to be recorded, the importer will not be able to claim ITC. And, the amount will reflect under total tax paid but ITC not claimed. Which will help authorities in keeping close watch upon the transaction which have been incurred but missed to be accounted for.

Explain, the ITC reclaimed under table 6 H of Annual Return.

For understanding ITC reclaimed let us move step by step and first talk about what is ITC claimed. ITC claimed is a situation where we have originally availed ITC but have neither paid the purchase consideration nor the amount of tax to the supplier within 180 days. Which eventually resulted in reversal of ITC so claimed. But, somelater the ITC was claimed again (reclaimed) on clearing the dues. One example to this situation is:

Total ITC availed – Rs 2,00,000/-
ITC reversed – Rs 20,000/-
(due to non-payment of value including tax to the supplier)
ITC reclaimed – Rs 11,000/-
( after payment made to the supplier)
Now, the disclosure in annual return shall be made as under
Table 6B Rs 1,89,000 (2,00,00 – 11,000)
Table 6H Rs 11,000 (ITC Reclaimed)
Table 7A Rs 9,000 (20,000 – 11,000)

What shall be the disclosure in Annual Return for the Disputed Credit availed and reversed under the protest?

The GST law does not provide for reversal of credit under protest. Hence, there is no separate disclosure available in the Annual Return for the same. The registered person may file a separate communication with the jurisdictional officer for such reversals made and no separate disclosure can be made in the Annual Return.

What if CGST and SGST credit has been availed as IGST Credit? How can the same be rectified in Annual Return?

Circular No.26/2017 dated 29.12.2017 provides that such transactions can be rectified wherein assessee needs to reverse the credit improperly availed and re-avail the correct credit through adjustments in the subsequent GSTR-3B and correct credit needs to be disclosed under the appropriate heads under Sl.No.6 under Part III of the Annual Return.

Whether credit of invoices not appearing in the GSTR-2A be reversed in the Annual Return?

Sl.No.8 under Part III appears to provide for disclosure of additional information required to be reported by the Assessee, with respect to matching of credit balances with Form GSTR-2A. There is no specific requirement for reversal of credit on account of invoices not reported in Form GSTR-2A. However, the details reported in Sl.No.8 would become the basis for the Department to determine in case of input tax credit availed in excess of credits reported in Form GSTR-2A.

Can adjustment be made in the Annual Return for Excess credit reversed in the year under Rule 42?

The form provides for reporting of actual reversals made in Form GSTR-3B for the FY 2017-18. Reversals made during FY 2018-19 w.r.t. FY 2017-18 would be required to be reported as part of the Annual return for FY 2018-19. However, the same may be shown in the Part V Table 13 merely for disclosure purpose.

Credit which was wrongly taken in TRAN-I has been reversed in GSTR-3B of September 2018. What shall be its disclosure in annual return?

Reversal of credit availed under TRAN-I is to be reported under Table 7(F) of the Annual Return when the reversal is made within same financial year. However, if the reversal is made after the end of year, it may be shown under Table 12 of GSTR-9.

State the disclosure requirements for credits carried forward in the TRANS-I and TRANS-II, in the Annual Return?

The details of input tax credit availed in Form TRAN 1 needs to be separately disclosed under Sl.No.6(K) and 6(L) under Part III of Annual return.

Input tax credit has been shown net of reversals in Form GSTR-3B. How the same shall be reported in Annual return?

The assessee has shown ITC net of credits i.e. reversals have not been disclosed separately. To ensure completeness of disclosures as per law assessee shall report

  • Gross input tax credit availed under Part III Sl.No.6 and,
  • Credit reversed under Part III Sl.No.7

This would ensure completeness of reporting of gross credits and reversals made during FY 2017-18. Also, the amount of ITC available for utilisation (as computed under Sl.No.7(J)) would be net of reversals and also in line with the total credit availed in Form GSTR-3B.

When ISD credit is incorrectly reported in GSTR-3B Form under ‘All other ITC’. Where should the correct disclosure be made in the Annual return?

While filing the annual return the gross amount of ITC is auto picked form GSTR 3B under Part III Sl.No.6. In addition to which break up needs to be provided by the taxpayer in annual return himself. So, if a person has made incorrect disclosure of Input Service Distributor credit while filing GSTR 3B the same should be correctly reported in annual return.

Input tax credit has been shown in the books of account but not shown in the GSTR-3B. Is some adjustment required to be made in the Annual Return?

Annual Return provides for reporting of such transactions which have been reported in the monthly returns. Credits availed in books of accounts and not reported in Form GSTR-3B shall not be reported in the Annual Return. Such credit would be reported in the GSTR-9C and difference has to be explained by the auditor.

In the absence of data integration with ICEGATE, whether IGST credit availed would also be compared with Form GSTR-2A?

Sl.No.8 under Part III which requires disclosure of certain additional details, compares the credit reported under Sl.No. 6(B) and does not include IGST credit availed on import of goods. Such credit has to be separately reported by the registered person.

For Credit reversed on account of non-payment of consideration to vendor, both in the FY 2017-18 and after the end of year (for invoices pertaining to last FY). What shall be the disclosure made in Annual Return?

The form provides for reporting of actual reversals made in Form GSTR-3B for the FY 2017-18 in the Table 7A of Annual Return. Reversals made during FY 2018-19 w.r.t. FY 2017-18 would require to be reported as part of the Annual return for FY 2018-19. Similarly, credits which have been reclaimed in Form GSTR-3B filed for FY 2017-18 shall be reported under Sl.No.6(H) under Part III.

What shall be the disclosure of Transitional credits made in Form GSTR-3B filed in FY 2018-19?

The form provides for reporting of actual reversals made in Form GSTR-3B for the FY 2017-18. Reversals made during FY 2018-19 w.r.t. FY 2017-18 would be required to be reported as part of the Annual return for FY 2018-19.

If there is any unavailed input tax credit pertaining to FY 2017-18, will the same lapse once the annual return is filed?

Yes, as per Section 16 of the CGST Act,2017 any unavailed input tax credit pertaining to FY 2017-18 would lapse either on the due date of filing GST return for the month of September 2018 or the date of filing annual return, whichever is earlier.

Should Amount of ITC claimed is to be reported in the GSTR 9?

Reporting of annual reversal of ITC required under Section 17 of the CGST Act,2017 may not be required since the provision also requires reversal of credit, along with applicable interest. Since it is an independent requirement to reverse/re-avail such credits, a view can be taken that the same may not be reported in Table V of the Annual Return

How blocked credit under section 17 (5) shall be disclosed in the Annual return?

There is mere disclosure requirement of blocked credit in GSTR-3B Table 4D without having any impact on the computation of credits. However, as per the format of the Annual Return, the amount of input tax credit reversed under Section 17(5) of the CGST Act,2017 would be reduced from the gross input tax credit availed. In case the Assessee has availed (in Table 4A) as well as reversed credits (in Table 4B) which have been restricted under Section 17(5) in Form GSTR-3B, the same reporting can be followed in the Annual Return. For all other assessees who have not availed the credit and merely disclosed the same in the Table 4D, they may choose not to report the same in the Annual Return, considering the net impact to be Nil. One may expect to have some amendment in the form w.r.t. disclosure of such ineligible credits.

A taxpayer sold goods in one financial year and due to some reason goods were returned in next financial year, for which a credit note was issued then. How shall this be reported in GSTR 9?

Say, In this case credit note has been issued for expired goods. Which is an after sales event. Hence the same is not required to be reported under the annual return. Instead, a disclosure of the ITC reversed u/s 17(5) on such sales shall be reported in GSTR 3B of the month of September 2018. The summary reporting of which will automatically be a part of annual return to be filed till 31st December 2019 i.e. annual return for the next Financial Year 2018-19.

Can credits appearing in GSTR-2A whose physical invoice is not available, be availed in the Annual Return?

Credits in annual return are reported on the basis of GSTR 3B filed by the taxpayer under Part III Sl.No.6. Later, if an assessee finds some other credits missed to be claimed as per GSTR 2A, and the same matches with his own records. It shall be reported in GSTR 3B till the month September.
The credits shall always be supported by a copy of invoice or equivalent document. In absence of which, the taxpayers may not be allowed to avail the ITC.

Is it mandatory to bifurcate input tax credit between inputs, input service and capital goods?

Yes, Sl.No.6 under Part III requires bifurcation of input tax credit availed under inputs, input service and capital goods.

Can reconciliation of GSTR-2A with ITC availed in GSTR-3B done at aggregate level or is required to be disclosed on invoice to invoice basis in GSTR 9?

Annual Return does not require line by line reconciliation of invoices as per GSTR 2A and 3B. Under Part III Sl.No.8 information is required with respect to matching of credit balances with Form GSTR-2A. So, a taxpayer may also match the balances vendor wise. However, the details reported in Sl.No.8 would become the basis for the department to determine, credit availed in excess of GSTR 2A on overall basis.

How benefits availed by a company of taking input credit as result of demerger be disclosed in annual return?

The recipient company needs to disclose the details in annual return under Part III, Sl. No. 6 and Table field (M). Against the heading “Any other ITC availed as not specified above”. Doing this will ensure the reporting requirement for the new company. In prior of which, to successfully claim such credits the reporting company shall file form ITC-02 on the common portal.

How the wrongly availed credit identified in the course of statutory audit should be reversed?

The credit needs to be reversed in GSTR 3B for the period in which the fact has come to knowledge of the assessee. If the same has been reversed in GSTR 3B then only can be reported in annual return. Which means, if the changes have been done till GSTR 3B for the month of Sep 2018 then, the same will be reported under annual return for FY 2017-18 to be filed till 31st Dec 2018. And, if the changes have been given effect any time later it shall be reported under next FY i.e. 2018-19 annual return.
Annual Return has no reporting option as to, ITC yet to be reversed or ITC to be cancelled in future. Hence ITC already reversed in GSTR 3B can only be reported.

Whether any disclosure is required in the Annual Return for Goods sent to a job worker for which ITC-04 has been filed in the Financial Year?

Goods sent to job worker on delivery challan are not in the nature of supply provided the goods are received back within the specified period. There is no requirement of disclosure of such removal in the Annual Return. However, if the goods are not received back within specified time period, it is treated as if supply has been made on the date of original removal of goods and tax has to be paid by the principal. Such instances have to be reported in the table 4 and Table 16B of the Annual Return.

An assessee was unregistered for some part of the previous financial year. ITC paid under RCM has been availed for the same. What disclosure should be made in annual return?

Separate disclosure is required to be made under Sl.No.6(C) and 6(D) under Part III for supplies received from registered and unregistered persons, respectively. Hence, reporting shall be made under Sl.No.6(c) for the period the supplier was unregistered (i.e. for invoices issued without his GSTIN) and for the balance period to be reported under Sl.No. 6(D).

CA Abhishek Soni
CA Abhishek Soni

Abhishek Soni is a Chartered Accountant by profession & entrepreneur by passion. He is the co-founder & CEO of Tax2win is amongst the top 25 emerging startups of Asia and authorized ERI by the Income Tax Department. In the past, he worked in EY and comes with wide industry experience from telecom, retail to manufacturing to entertainment where he has handled various national and international assignments.