Introduction:-
GSTN recently issued an Advisory on table 8A of GSTR-9. This advisory has 5 issues regarding reporting system in GSTR-9, In this article we discuss Issue-1 along with the Practical problem in complying the same are provided below:-
Situation / Issue-1:-
Invoice having the date of FY 23-24 but the supplier has reported in the GSTR 1 after the due date of March 24. As a result, this amount is not auto populated in the Table 8A of GSTR 9 for FY 2023-24 because it is the part of next year’s GSTR 2B. How to report such transaction in the GSTR 9 of FY 23-24?
Reporting as per GST Advisory:-
Taxpayer shall report such ITC in the Table 8C and in Table 13 as this is the ITC of FY 2023-24. This is in line with the instructions to the Table 8C and Table 13 of GSTR 9.
Analysis:-
Reporting of this ITC in Table-13 is correct because ITC as per books of accounts for FY 23-24 has been claimed in FY 24-25. However Table-8 having heading “Other ITC related information” is not relate to ITC as per books of accounts. Because Table-8 is nothing but a reconciliation of ITC claimed in return GSTR-3B with ITC appeared in GSTR-2B.
Table-8C is for “ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next financial year up to specified date“. Means ITC of Table-8C is not related to books of accounts, but for FY 23-24, ITC on inward supply that was received in FY 23-24 but availed in return GSTR-3B for FY 24-25 (upto 30.11.24)to be reported in this Table-8C.
However as we mentioned above that Table-8A and 8B is for reconciliation of ITC available in GSTR-2B with ITC claimed in GSTR-3B,so ideally in Table-8C, this ITC figure should not be appear because it is not a part of GSTR-2B as well as GSTR-3B. If we will report this ITC in Table-8C according to advisory then the figures of Table -8D will appear negative because this ITC is not reflecting in Table-8A (figure of GSTR-2B) and Table-8B (figure of GSTR-3B).
As we all know that SCN is issuing if Table-8D having negative figure, if we report in Table-8C then Table-8D will appear negative and may lead to situation of facing potential Show Cause Notice for the said difference .
Conclusion:-
As discussed above Table-8 is not comparison of ITC with books of accounts but a comparison between ITC figures as per GSTR-2B and 3B and also given the practical challenges outlined, the author believes that such ITC should not be reported in Table 8C but should be reported in Table 13 only, despite the suggestion given in the advisory because advisory is not a part of GST Law.
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