In light
of Notification No. 12/2024 - Central Tax dated 10th July 2024,
read with Notification No. 20/2024 - Central Tax dated 8th October
2024, changes in reporting for Form GSTR-9 have been introduced for FY
2023-24 onwards. The total input tax credit (ITC) available for
inward supplies is now auto-populated in Table 8A of GSTR-9 based on GSTR-2B
for the respective financial year.
Meanwhile,
Table 8C of GSTR-9 requires manual entry of ITC on inward supplies
received during the FY but availed in the next FY within the permissible
period. This change has raised several queries regarding mismatches between the
values in Table 8A and Table 8C, particularly due to differences in data
sources (GSTR-2A for FY 2022-23 and GSTR-2B for FY 2023-24). Below are common
issues and recommended solutions to ensure compliance and accurate reporting:
Common Scenarios and Reporting Guidelines
1. Invoice Dated FY 2023-24, Reported Late in
GSTR-1
Issue: The supplier files GSTR-1 post-March 2024, making the invoice part of
the next year’s GSTR-2B.
Solution:
- Report
this ITC in Table 8C and Table 13 of GSTR-9 for FY 2023-24,
as it pertains to the current FY.
- Align
reporting with the instructions for Table 8C and Table 13 of Form GSTR-9.
2. ITC Claimed and Reversed in FY 2023-24,
Reclaimed in FY 2024-25
Issue: ITC is reversed due to non-payment to the supplier within 180 days (as
per Section 16(2)) but reclaimed after payment in FY 2024-25.
Solution:
- Report
the reclaimed ITC in Table 6H of GSTR-9 for FY 2024-25.
- Do not
include this in Table 8C or Table 13 of GSTR-9 for FY
2023-24.
- This
approach applies to reclaims under Rule 37A as well.
3. ITC Claimed, Reversed, and Reclaimed Due to
Goods Received Late
Issue: ITC claimed in FY 2023-24 and reversed due to non-receipt of goods (as
per Circular 170), then reclaimed in FY 2024-25.
Solution:
- Report
reclaimed ITC in Table 8C and Table 13 of GSTR-9 for FY
2023-24.
4. FY 2022-23 Invoice in Table 8A of FY 2023-24
Issue: Supplier files GSTR-1 late, causing FY 2022-23 invoices to appear in
Table 8A of FY 2023-24.
Solution:
- Exclude
these values from Table 8C and Table 13 of GSTR-9 for FY
2023-24.
- Report
only current FY data in Tables 4, 5, 6, and 7, per Instruction 2A of the
notified form.
5. ITC Claimed, Reversed, and Reclaimed in the Same
FY
Issue: Invoice ITC is claimed, reversed, and reclaimed within FY 2023-24.
Solution:
- Declare
this ITC in Table 6H of GSTR-9.
- Do not
duplicate reporting under Table 7 or elsewhere, as clarified by the CBIC
press release dated 3rd July 2019.
Key Takeaways
- Understand
the source differences (GSTR-2A vs. GSTR-2B) and how they impact
auto-population.
- Ensure
that only current FY transactions are reported in relevant tables.
- Reclaimed
ITC should be correctly reported based on timing and instructions for
specific tables.
By
adhering to these guidelines, taxpayers can minimize mismatches and ensure
accurate compliance with the revised norms for FY 2023-24 annual returns.
