Summary: On December 9, 2024, the Goods and Services Tax Network (GSTN) issued an advisory addressing discrepancies in Table 8A of GSTR-9 for FY 2023-24. The issue arises due to a change in how values in Table 8A are auto-populated. While previously derived from GSTR-2A (dynamic return), the values now come from GSTR-2B (static return). However, problems have surfaced due to the B2BA (amendments) schedule in GSTR-2B. These amendments often lead to double counting of invoices in Table 8A when invoice details are revised by suppliers after initial filing. For instance, if a supplier amends an invoice number, it appears in both the B2B and B2BA schedules of GSTR-2B for the same financial year, resulting in inflated ITC in Table 8A of GSTR-9. This discrepancy impacts taxpayers in two ways. First, if ITC is wholly availed based on GSTR-2B, excess ITC may be claimed, requiring repayment with interest. Second, during annual return filing, Table 8A reflects inflated ITC values, necessitating reconciliation with books of accounts. The advisory suggests comparing invoices in the B2BA schedule with those in the B2B schedule to identify and eliminate duplicate entries for accurate reporting.
Error in Table 8A of GSTR-9 for FY23-24
On Dec 9th, 2024, Goods and Services Tax Network issued an Advisory on difference in value of Table 8A and 8C of Annual Returns FY 23-24
The advisory covered various issues being faced in filing Annual Return for FY23-24 due to change in Table 8A of GSTR-9.
Change in Table 8A of GSTR-9: Upto FY22-23, Values in Table 8A used to be auto-populated based on GSTR-2A of the months of the financial year. From FY23-24, Values in Table 8A will get auto-populated from GSTR-2B of months of the financial year instead of GSTR-2A.
The above-mentioned advisory covered various concerns in reporting but was unable to address issues being faced by Taxpayers due to B2BA (Amendments) Schedule of GSTR-2B.
Background:
- B2BA Schedule of GSTR-2B covers amendments/changes to inward supplies made by registered businesses.
- Table 8A of GSTR-9 contains ITC as per GSTR-2B (excluding RCM and Imports)
- Table 8A of GSTR-9 = B2B Invoices + Debit Notes in CDNR – Credit Notes in CDNR + B2BA invoices having Invoice Date of FY23-24
- Table 8 of GSTR-9 compared ITC available as per GSTR-2B with ITC availed in GSTR-3B to determine any shortfall or excess ITC availed.
- GSTR-2A is a Dynamic Return but GSTR-2B is a Static return which gets freezed each month.
Issue:
- Suppose we purchased goods worth Rs.1,000/- (+ IGST Rs. 180/-) in the month of Apr’23 having Invoice Number FY23-24/001. It will be reflected in B2B Schedule in our GSTR-2B of Apr’23.
- In July’23, the supplier identifies that the above-mentioned Invoice Number is incorrect which should be FY23-24/002. He amends the Invoice is his GSTR-1 of July’23 changing the invoice number from FY23-24/001 to FY23-24/002. This invoice will be reflected in our GSTR-2B of July’23 in B2BA Schedule having updated Invoice Number (all other details being the same)
- While preparing Auto-Populated Table 8A of GSTR-9, GST Network will consolidate all GSTR-2B of the months of FY23-24.
- Here, in GSTR9 of FY23-24, Portal is counting the above stated invoice twice; one from B2B Schedule of Apr’23 and one from B2BA Schedule of July’23, resulting in double counting of ITC despite the fact that only Invoice Number was amended in July’23
Impact:
- In Monthly Compliance: If the Taxpayer avails GST Input wholly on basis of GSTR-2B, it will result in excess availment of ITC since the second invoice of July’23 does not entitles ITC to the Taxpayer. The Excess ITC such availed needs to be paid back alongwith applicable interest
- In Annual Return: Table 8A of GSTR9 contains value of both these invoices. This results in inflated value of Table 8A which needs to be rectified while reconciling the ITC with Books
Solution: In Order to address this issue, Invoices of Schedule B2BA should be compared with Invoices in Schedule B2B to identify such double invoices which needs to be eliminated.
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Author: Dhruv Gupta | CA Finalist | B.Com.(Hons.)’24 DU Regular
