While filing an annual return (GSTR-9) under GST, numerous taxpayers find mismatch in ITC as per auto populated details in annual return and the data available in their GSTR-2A, which results in preparation of lot of reconciliation reports by the professionals in order to arrive at a figure shown in Table 8A. But if all goes pear shaped then they raise a grievance at [email protected] and receive an automated reply from GSTN which states the below mentioned basic reasons for mismatch:
1) Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-1 of the supplier taxpayer. But figures in table 8A of Form GSTR-9 are auto-populated only on the basis of filed Form GSTR-1 by the supplier taxpayer. In case, Form GSTR -1 is not filed by your supplier, then credit related to those invoices will not appear in table 8A of your Form GSTR-9.
2) Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR-1, which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 31st May, 2019, will not get auto-populated in table 8A of Form GSTR-9.
3) In ITC values in form GSTR-9 → Table 8 → point A, if supplier is not having Reverse charges (values: “N”) is considered for ITC calculations shown here. And if supplier is having Reverse charges (values: “Y”) will not be considered for ITC calculations.
4) In table 8A of Form GSTR-9, only latest values have been auto-populated based on filed Form GSTR-1, taking into account all the amendments made,
5) In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in which place of supply lies in supplier’s taxpayers State, instead of State of the receiver taxpayer. These figures will be shown in Form GSTR-2A of the recipient.
6) The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.
7) Receiver should not be SEZ. If SEZ, 8A would be populated as zero.
8) IMPORTANT : All invoices/Notes and their amendments belonging to FY 2017-18 uploaded and filed till 31st May, 2019 only will be considered for calculations.
Mismatch between ITC values in form GSTR-2A data in “Credit and Liability Statement” Report and ITC values in GSTR-2A form: – Please note that for GSTR-2A form, if you have saved any GSTR-1 form and not filed it, ITC of that value will get displayed in GSTR-2A form. But only filed GSTR-1 form ITC values will be displayed in “Credit and Liability Statement” Report→ ITC Credit Report. It will not consider if any GSTR-1 form is only saved and not filed.
But due to a complexity, it can be a possibility that the mismatch of ITC amount in Form GSTR-9 and Form GSTR-2A may occur even after analysing all possible reasons. In light of this, a new Tab has been enabled on GST Portal “Download Table 8A Document Details” while filing GST Annual Return in which a list of invoices appearing in Table 8A of GSTR-9 is available now.
Now, this button will be a silver bullet for all ITC mismatch problems while filing an annual return which will enable the taxpayers to download the invoice-wise details which are being reflecting in Table-8A of GSTR-9 in an excel format along with the reason for non-accounting for F.Y.2018-19.
A Screenshot of B2B data available through this option is given below:
Points to remember:
1. Invoice-wise detail for invoices appearing in Table-8A of GSTR-2A is only for Y. 2018-19 in excel format.
2. B2B, B2BA (amendments in B2B, CDNR and CDRNA (amendments in credit notes) data will be available.
3. 31st Oct, 2019 is the cut-off date considered for ITC as per Notification No. 56/2019- Central Tax dated 14-11-2019.
You may find a mismatch with data available in Table 8A of GSTR-9 and data available in the excel sheet provided through this tab.There is a technical glitch in the excel sheet as GSTN enabled only one validation check i.e., details uploaded by the all suppliers in their GSTR-1 till 31st Oct, 2019 is available.
Along with the above validation check, it should also enable another validation check i.e., only data uploaded by all the suppliers in their GSTR-1 pertains to F.Y. 2018-19 should be available.
In order to match your data with Table 8A of GSTR-9,we suggest our readers to modify this sheet by deleting all entries starting from Apr,2019 as it pertains to F.Y. 2019-20 then your data will definitely match with Table 8A of GSTR-9.
Disclaimer: The views presented are in personal and generic form and not as a legal advice. Users of this information are expected to refer to the relevant existing provisions of the applicable laws.
The author may be reached at [email protected]