CBIC Notifies to Reconcile ITC from GSTR-2B Instead of GSTR-2A in Form GSTR-9

By: Admin
October 10, 2024
Categories: 54th GST Council
4 Min Read

Background:

Previously, taxpayers were required to reconcile the Input Tax Credit (“ITC”) availed in FORM GSTR-3B with the details reflected in FORM GSTR-2A. This requirement was established by sub-rule (4) inserted to Rule 36 of the Central Goods and Services Rules, 2017 (“the CGST Rules”), effective from October 09, 2019. This obligation was also reflected in Table 8 of FORM GSTR-9, where taxpayers reconciled the ITC claimed with the figures in FORM GSTR-2A. For reference, the contents of Table 8(A) of FORM GSTR-9 are outlined below:

Other ITC Related Information

Now:

The CBIC, through Notification No. 20/2024 – Central Tax dated October 8, 2024, has updated the reconciliation process, replacing ITC as per GSTR-2A with ITC as per GSTR-2B. The amendment is as follows:

“17. In the said rules, in FORM GSTR-9, in the table, in Pt. III, in serial number 8, for serial number A and the entries relating thereto, the following serial number and entries shall be substituted, namely:

“A
ITC as per GSTR-2B (table thereof)

”

Prior to this change, it was as follows:

Our Comments:

The CBIC, via Notification No. 82/2020–Central Tax dated November 10, 2020, previously amended Rule 61 to introduce FORM GSTR-2B, effective from January 01, 2021. To provide statutory backing for claiming ITC per FORM GSTR-2B, the Finance Act, 2021 added clause (aa) to sub-section (2) of Section 16 of the CGST Act:

“(aa) the details of the invoice or debit note referred to in clause (a) have been furnished by the supplier in the statement of outward supplies and such details have been communicated to the recipient of such invoice or debit note in the manner specified under section 37;”.

Subsequently, with Notification No. 39/2021–Central Tax dated December 21, 2021, additional amendments to the Finance Act, 2021 were enacted, fully substituting Rule 36(4) of the CGST Rules effective January 01, 2022. The amended Rule 36(4) reads:

“(4) No input tax credit shall be availed by a registered person in respect of invoices or debit notes the details of which are required to be furnished under sub-section (1) of section 37 unless,

(a) the details of such invoices or debit notes have been furnished by the supplier in the statement of outward supplies in FORM GSTR-1, as amended in FORM GSTR-1A if any, or using the invoice furnishing facility; and

(b) the details of input tax credit in respect of such invoices or debit notes have been communicated to the registered person in FORM GSTR-2B under sub-rule (7) of rule 60.”

From January 01, 2022, registered persons are required to claim ITC that only appears in FORM GSTR-2B.

To align with these changes, the CBIC has now substituted FORM GSTR-2A with FORM GSTR-2B for reconciliation purposes. Taxpayers must now reconcile the ITC availed in FORM GSTR-3B with the details in FORM GSTR-2B under Table 8 of FORM GSTR-9, simplifying compliance requirements.