GST Council in its 39th meeting held on 14th March 2020 had recommended to adopt and implement the incremental approach of linking the present system of filing of FORM GSTR-1 (details of the statement outward supplies) to the liability FORM GSTR-3B. This would be followed by the linking of the input tax credit in FORM GSTR-3B to the details of the supplies reflected in the FORM GSTR-2A.

One such enhancement that the Council recommended was introduction of an auto-drafted input tax credit (ITC) statement which would aid in assisting / determining the input tax credit that is available for every taxpayer i.e. GSTR-2B. The government will be launching form GSTR-2B for the proper availment & utilisation of Input Tax Credit. The new form will help the government as well as the taxpayers in matching input and output of ITC in forms GSTR-3B, GSTR-1 and GSTR-2A, accordingly it enable the government in curbing tax evasion. It is expected that GSTR-2B will help in reduction in time taken for preparing return, minimizing errors, assist reconciliation & simplify compliance relating to filing of returns.

GSTR-2B would assist taxpayers in return filings are as under:

i. It contains information on import of goods from the ICEGATE system including inward supplies of goods received from Special Economic Zones Units/ Developers.

ii. A summary statement which shows all the ITC available and non-available under each section. The advisory given against each section clarifies the action to be taken by the taxpayers in their respective section of GSTR-3B.

iii. Document level details of all invoices, credit notes, debit notes etc. is also provided both for viewing and download.

Key features in GSTR-2B:

1. GSTR2B is an auto-drafted ITC statement which will be generated for every registered person (except person registered for composition dealer under Section-10) on the basis of the information furnished by his suppliers in their respective GSTR-1(Outward supplies details), GSTR-5 (non-resident taxable person) and GSTR-6 (input service distributor). The statement will indicate availability of input tax credit to the registered person against each document filed by his suppliers.

2. GSTR-2B return is a static statement will be generated for each month on the 12th day of the succeeding month. A PDF and email feature is also added to the form for the ease of assessee. The form will show whether ITC is available to the assessee or not. The form will summarize the ITC credits attached with GSTR-3B and get to know details on GSTR-3B form along with the online return filing procedure.

3. GSTR-2B for a month (M) will contain the details of all the document filed by his suppliers in their respective GSTR-1, GSTR-5 and GSTR-6 between the due date of furnishing of GSTR-1for previous month (M-1) to the due date of furnishing of GSTR-1 for the current month (M).

4. There may be instances where the date of filing of GSTR-5 (Non-Resident taxable person) and GSTR-6 (Input Service Distributor) may be later than the date of generation of GSTR-2B. Under such circumstances, taxpayers are advised to avail input tax credit on self-assessment basis. However, when such document gets filed and reflected in their next GSTR-2B, taxpayers shall not avail such input tax credit.

5. The documents furnished by the supplier in any GSTR-1, GSTR-5 and GSTR-6 would reflect in the next open GSTR-2B of the recipient irrespective of the date of issuance of the concerned document.

6. The tax paid on reverse charge basis i.e. on import of services is not a part of this statement and ITC on RCM will be continued to be entered by taxpayers in Table 4 (A)(2) of FORM GSTR-3B.

7. Table 3: ITC available summary captures the summary of ITC available as on the date of generation of FORM GSTR-2B.

8.  Table 4: ITC not available summary captures the summary of ITC not available as on the date of generation of FORM GSTR-2B. Credit reflected in this table shall not be entered in Table 4(A) of FORM GSTR-3B.

9. Credit shown as “ITC Not available” in Table 4, Invoice or debit note for supply of goods or services or both where the recipient is not entitled to ITC as per the provisions of sub-section (4) of Section 16 of CGST Act, 2017 and Invoice or debit note where the supplier (GSTIN) and place of supply are in the same State while recipient is in another State.

10. GSTR-2B generated on the basis of own records and books of accounts, taxpayers are not permitted to avail ITC twice for any document under any circumstances. Hence, Credit shall be reversed as per GST Act and Rules in FORM GSTR-3B. Tax on RCM basis shall be paid.

11. A taxpayer can access the GSTR-2B by navigating to the GST Portal then click on Returns Dashboard then click on Select Return period and then GSTR-2B, after login to the portal.

12. Details of all the documents in GSTR-2B are made available online as well as through download facility. So this form can be downloaded in PDF, Jason file and Excel version.

13. File Returns page will appear, here using the drop-down menu select the Financial Year & Return Filing Period (Month) for which taxpayer wants to view / download Form GSTR-2B from the common portal.

The details of Tables along with instructions of FORM GSTR-2B are summarized in the below Table:

Table Particulars Part / Section Instructions
Table-3 ITC available

All other ITC-Supplies from registered persons other than reverse charge.

B2B – Invoices

B2B – Debit notes

B2B – Invoices (Amendment)

B2B – Debit Notes (Amendment

Part-A Section -I i. This section consists of the details of supplies (other than those which tax is to be paid on reverse charge basis), which have been declared and filed by your suppliers in their FORM GSTR-1 and GSTR-5.

ii. Negative credit, if any, may arise due to amendment in B2B- Invoices and B2B-Debit notes. Such credit shall be reversed in Table 4 (B) (2) of FORM GSTR-3B.

Table-3 ITC available

Inward Supplies from ISD.

ISD – Invoices

ISD – Invoices (Amendment)

Part-A Section –II i. This section consists of the details of supplies, which have been declared and filed by an input service distributor in their FORM GSTR-6

Negative credit, if any, may arise due to amendment in ISD Amendments- Invoices; Such credit shall be reversed in table 4(B) (2) of FORM GSTR-3B.

Table-3 ITC available

Inward Supplies liable for reverse charge.

B2B – Invoices

B2B – Debit notes

B2B – Invoices (Amendment)

B2B – Debit Notes (Amendment)

Part-A Section-III i. This section consists of the details of supplies on which tax is to be paid on reverse charge basis, which have been declared and filed by the suppliers in FORM GSTR-1.

ii. These supplies shall be declared in Table 3.1(d) of FORM GSTR-3B for payment of tax. Credit may be availed under Table 4(A)(3) of FORM GSTR-3B on payment of tax.

Table-3 ITC available

Import of Goods

IMPG  –Import of goods from overseas

IMPG (Amendment)

IMPGSEZ – Import of goods from SEZ

IMPGSEZ (Amendment)

Part-A Section IV i. This section provides the details of IGST paid on import of goods from overseas and inward supply of goods from SEZ units / Developers on bill of entry and amendment thereof. These details are updated on near real time basis from the ICEGATE system.

ii. This table contains date is the date from which the recipient is eligible to take input tax credit.

iii.The ICEGATE reference date is the date from which the recipient is eligible to take input tax credit.

iv.The table also provides if the Bill of entry was amended.

v.Information is provided in the tables based on data received from ICEGATE. Information on certain imports such as courier.

vi. This data will be made available from GSTR-2B of August’2020 onwards (i.e. 12’th September, 2020).

Table-3 ITC available Others Part-B Section-I i. This section consists of the details of credit notes received and amendment thereof which have been declared and filed by your suppliers in their FORM GSTR-1, GSTR-5 and GSTR-6.

ii.Such credit shall be reversed under Table 4(B) (2) of FORM GSTR-3B. If this value is negative, then credit may be reclaimed subject to reversal of the same on an earlier instance.

Table-4 ITC not available

All other ITC- Supplies from registered persons other than reverse charge

Part-A Section-I i. This section consists of the details of supplies (other than those on which tax is to be paid on reverse charge basis), which have been declared and filed by the suppliers in their FORM GSTR-1 and GSTR-5 but satisfy the conditions mentioned at Sr. No. 9 above.

ii.This is for information only and such credit shall not be taken in FORM GSTR-3B.

Table-4 ITC not available

Inward Supplies from ISD

Part-A Section-II i. This section consists of the detail of supplies, which have been declared and filed by an input service distributor in their FORM GSTR-6 but satisfy the two conditions mentioned at Sr. No. 9 above.

ii. This is for information only and such credit shall not be taken in FORM GSTR-3B.

Table-4 ITC not available

Inward Supplies liable for reverse charge

Part-A Section -III i. This section consists of the details of supplies liable for reverse charge, which have been declared and filed by the suppliers in their FORM GSTR-1 but satisfy the conditions mentioned at Sr. No.9 above.

ii. This is for information only and such credit shall not be taken in FORM GSTR-3B.

Table-4 ITC not available

Others

Part-B Section-I i. This section consists of the details of credit notes received and amendment thereof which have been declared and filed by the suppliers in their FORM GSTR-1, GSTR-5 and GSTR-6 but satisfy the conditions at Sr. No. 9 above.

ii.Such credit shall be reversed under Table 4(B) (2) of FORM GSTR-3B.

Comparison between Auto-populated GSTR-2A and GSTR-2B:

GSTR-2A and GSTR-2B both returns are auto-populated on monthly basis. Both returns guide to the taxpayers for availing input tax credit available to them. The comparison between them can be summarized as under:

Key parameters GSTR-2A GSTR-2B
Type of Statement It is progressive / dynamic in nature, as this changes from day to day, as and if the supplier uploads the documents. It is static or constant in nature, as the GSTR-2B for one month cannot modify based on future operations of the supplier.
Frequency of Return     Monthly    Monthly
Information  Derive Source GSTR-1, GSTR-5, GSTR-6, GSTR-7 & GSTR-8 GSTR-1, GSTR-5, GSTR-6, ICEGATE system.
Input Tax Credit on Import of Goods. No information available for taking ITC on imported goods. Allowed ITC on imported goods as obtain from ICEGATE system (available from GSTR-2B of August, 2020 onwards.

Conclusion: The new FORM GSTR-2B is an auto-generated ITC statement, it will be generated ON for every month with effect from August’2020 and for the month of August’2020 will be available on 12’th September’2020.  GSTR-2B is static statement not dynamic like GSTR-2A. It provides a summary of the inward supply and applicable ITC that can be claimed / reversed in the relevant headings in Form GSTR-3B. It also provides a summary of the inward supply along with ITC applicable that must be reversed or can’t be claimed in Form GSTR-3B. There is chances of blockage of ITC, as GSTR – 2B is reflecting entry of GSTR- 1 timely filed and therefore blocking ITC in the hands of recipient for late filing of GSTR-1 and quarterly filing of GSTR- 1. Unlike GSTR-2A there is no provision of capping of 10% ITC as per Rule 36(4) of CGST Rules, 2017, relaxation provided hence the taxpayers can avail full ITC without any restriction on the strength of monthly GSTR-2B return until the Government is thinking to bring any amendment in this regard. A taxpayer can view and download GSTR-2B from the GST portal. In the case where the total number of documents under all tables exceeds 1000 then the document details table will not be visible online. However, the taxpayer can download the GSTR-2B statement in excel or JSON file by clicking on download link. The link will be available in the message. The new version of the GSTR-2B return will link the existing return filing Forms GSTR-1, GSTR-5, and GSTR-6 and will help the Government in curbing tax evasion.

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