ITC Reconciliation under GST| GSTR-2B Vs Table-8A of GSTR-9

GST Annual return is an annual return filed in form GSTR-9 wherein aggregate information for complete year is required to be furnished about Output Tax Liability and Input Tax Liability. It is mandatory for every taxpayer to keep a reconciliation of information furnished in monthly/quarterly GST returns and Annual returns to avoid notices from GST authority.

With respect to Input Tax Credit, while filing GSTR-3B  (Monthly/Quarterly), Input Tax Credit is claimed as per ITC auto-populating in Table-4 of GSTR-3B. Such ITC auto-populates as per ITC appearing in GSTR-2B. However, while filing Annual return in form GSTR-9, auto-populating Input Tax Credit is difference from aggregate of ITC claimed in GSTR-3B (as per GSTR-2B). Therefore, it is important for every taxpayer to prepare of reconciliation of ITC appearing in Table-8A of GSTR-9 and ITC as per GSTR-2B of every month.

This article will assist you in preparation of such reconciliations and highlight what are the major factors causing difference in ITC as per GSTR-2B and ITC as per Table-8A.

1. What is Input Tax Credit as per GSTR-2B?

• As per GST Law, every taxpayer is entitled to claim Input tax credit with respect to inward supplies of goods and services during the month of procurement only if the supplier files his GSTR-1/IFF  till 11th or 13th of following months.
• If supplies files his GSTR-1/ IFF after the due date of filing of such return then ITC shall be available during the month in which GSTR-1 is filed.
• E.g. 

Date of Invoice: 15th Jan, 2024

• Accordingly, GSTR-2B is an auto-drafted ITC Statement which is generated by GST portal on 14th of following months based on GSTR-1 filed by the supplier till due date.
• GSTR-2B shall be prepared on the basis of information furnished by his suppliers in their respective:
  • GSTR-1, 
  • IFF( Invoice furnishing facility) 
  • GSTR-5 (non resident taxable person), and
  • GSTR-6 (input service distributor). 

• GSTR-2B can be accessed in excel format post login at GST portal at following link:

Dashboard>Services>Return>GSTR-2B (upon selection of Financial year and month)

Therefore, ITC in GSTR-2A auto-populates on the basis of date of filing of GSTR-1 of supplier irrespective of date of Invoice, i.e., pertaining to the same Financial year or earlier Financial year.

2. What is Input Tax Credit as per Table-8A?

• Table-8A is an auto-populated table prepared on the basis of GSTR-1 filed by the supplier for a Financial year.
• Major difference between ITC as per GSTR-2B and ITC as per Table-8A is the period for which ITC is appearing. In GSTR-2B, ITC reflected based on the date of GSTR-1 filing by the supplier. However, in case of Table-8A, ITC reflects for a single Financial year irrespective of date of filing of GSTR-1.
• E.g. 

Date of Invoice: 15th Jan, 2024

• While filing annual returns in Form GSTR-9, the taxpayer is required to report ITC in comparison with ITC auto-populating in Table-8A instead of GSTR-2B.

Why is it important to reconcile the ITC as per GSTR-2B and ITC as per Table-8A

• While filing GSTR-3B, ITC is claimed as per GSTR-2B (i.e, ITC based on GSTR-1 filed by the supplier). However, while filing GSTR-9, ITC is disclosed as per Table-8A, i.e., ITC pertaining to relevant financial year.
• Therefore, ITC disclosed in GSTR-9 is not equal to ITC claimed in GSTR-3B in most of the cases.
• Taxpayers are required to prepare necessary reconciliation of ITC claimed in GSTR-3B and ITC reported in GSTR-9 to ensure that no ineligible ITC is claimed by the supplier.
• Further, at the time assessment, the taxpayer may be required to submit such reconciliations to the Assessing authority.

What are the components of Reconciliation of ITC as per GSTR-3B and ITC as per Table-8A?

Following are the possible reasons for the difference in Input Tax credit appearing in GSTR-2B and ITC auto-populating in Table-8A of Annual return (Considering current FY is 2023-24, previous Financial year is FY 2022-23 and Following F.Y. 2024-25):

• ITC pertaining to previous Financial year (2022-23) reported in current Financial year (2023-24): There can be certain cases where supplier files GST return of FY 2022-23 in FY 2023-24 or report any of the invoice pertaining to FY 2022-23 in GST return of FY 2023-24. In such a case, such invoice shall reflect in GSTR-2B of FY 2023-24 of the recipient and Table-8A of FY 2022-23.

In such a case, while filing GSTR-9, the taxpayer shall disclose such ITC under column-”ITC pertaining to previous financial year and claimed in current Financial year”.

• ITC pertaining to current Financial Year (2023-24) reported in following financial year (FY 2024-25): Similar to above, if supplier files GSTR-1 of FY 2023-24 in FY 2024-25 or reports any of the invoice of FY 2023-24 in GSTR-1 of FY 2024-25 then such ITC shall reflect in GSTR-2B of FY 2024-25 and Table-8A of FY 2023-24.

The taxpayer such disclose such ITC in Column C of Table-8- “ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during 2023-24 but availed during 2024-25”

• Amendment made in GSTR-1 of Following year: If invoice reported in GSTR-1 of FY 2023-24 is amended in GSTR-1 filed in FY 2024-25 then ITC pertaining to original invoice shall reflect in GSTR-2B of FY 2023-24. Whereas, net impact of amendment of such invoice shall reflect in GSTR-2B of FY 2024-25. However, net ITC of such invoice shall reflect in Table-8A of FY 2023-24.

E.g.

• ITC on Import: GSTR-2B shall disclose the ITC on import of goods based on the bill of entry filed by the taxpayer at the time of clearance of goods from custom authority. Such ITC reflects in GSTR-2B of every month based on data transmitted from IECgate to GST portal. However, ITC on import shall not reflect in Table-8A.
• Cancellation of Input Tax Credit with retrospective effect: Presently, in many cases GSTIN of taxpayers are cancelled with retrospective effect on various grounds such as non-filing of GST return for continuous period of 6 months, non-compliance with provisions of GST law, taxpayer is involved in bogus purchase etc.

In case of cancellation of GSTIN with retrospective effect, invoices disclosed in GSTR-1 shall auto-populate in GSTR-2B of the recipient on the basis of date of filing of GSTR-1. However, invoices date falling after the effective date of cancellation of GSTIN shall appear as ineligible ITC in Table-8A.  Accordingly, such ITC shall form part of ITC as per GSTR-2B but not ITC as per Table-8A.

• ITC under Reverse Charge Mechanism: ITC under reverse charge mechanism is paid by the taxpayer as per expenses recorded in books of accounts. However, In table-8A only such ITC under RCM shall auto-populate which is reported by the supplier.

E.g.

Inward supplies liable to RCM: 

ITC as per Table-8A under RCM: INR 5,000

ITC as per GSTR-3B: INR 10,000

How to prepare Reconciliation of ITC as per GSTR-2B and ITC as per Table-8A?

Reconciliation of Input Tax Credit as per GSTR-2B and as per Table-8A shall be prepared in following manner:

Frequently Asked Questions

a. Just like GSTR-2A, whether ITC auto-populating in Table-2B shall update after the 14th of the following month?

GSTR-2B once generated shall not amend irrespective of the filing of GSTR-1 by the supplier. ITC auto-populating as per GSTR-2B shall not update even after cancellation of GSTIN of any of the suppliers with retrospective effect.

b. What is the date of generation of Table-8A?

There is no specific due date given under GST law for generation of Table-8A. From June or July month of the following year, tab for filing of annual return is enabled on the GST portal. Option to download Table-8A enabled after enabling the Annual return tab.

c. Whether ITC as per Table-8A keeps on updating?

The supplier has the option to file a GST return at any time or the supplier can amend the invoice reported in GSTR-1 till the following year. Therefore, Table-8A keeps on updating till invoices pertaining to relevant financial years are reported or filed by the supplier in their GSTR-1.

Conclusion

ITC is a major component of GST return and mis-calculation can lead to major demand under GST. ITC as per GSTR-2B and ITC as per Table-8A are different and taxpayers are required to prepare a reconciliation of the same so that the correct amount of ITC is claimed. As per different components of reconciliation, correct reporting is also to be made in GSTR-9 and GSTR-9C. Further, Where the GSTIN of the supplier is cancelled with retrospective effect then the taxpayer should make a necessary follow up with the supplier to get his GSTIN reactivated

Deepika Jain Partner

FCA| +10 years experience | Practitioner| Ex-KPMG| GST Expert| Trainer

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Finance GST Income Tax