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Introduction

GSTN has incorporated a new functionality on its portal by enabling GSTR 2B with effect from August 2020. GSTR 2B addresses the difficulties faced by the taxpayers in availment of Input Tax Credit and its reconciliation.

GSTR 2A, which also provides ITC detail, is dynamic in nature, and data keeps on changing as and when GSTR 1 is filed by the suppliers. Thus, difficulties arise in reconciling ITC with the books of account and takes unwarranted time.

Therefore, to overcome aforesaid difficulty, Government of India has devised new statement named GSTR 2B. GSTR 2B is a STATIC monthly auto drafted statement, generated based on GSTR 1 filed by the Suppliers during a particular period.

Availability of GSTR 2B

GSTR 2B will be made available monthly from August 2020 onward and will be ready to download/view on 12th day of every month. It will contain ITC information of all the documents filed by the supplier through GSTR1/5/6 during the period beginning from 12th day of the preceding month to 11th day of current month. Thus, statement generated for the month of August 2020, will contain the ITC information based on the data submitted in GSTR 1/5/6 by suppliers between August 12, 2020 to September 11, 2020.

Table given below will provide fair idea about different situation:

Date of filing of GSTR 1 by supplier Date of Invoice Will reflect in GSTR 2B of month To be taken in GSTR 3B of* Explanation
September 11, 2020 Aug 15, 2020 August, 2020 August, 2020
September 15, 2020 Aug 15, 2020 September, 2020 September, 2020 As GSTR1 has been filed late, credit will be reflected in next month
September 11, 2020 April 01, 2019 August, 2020 August, 2020 GSRT1 for April 2019 is filed in Sept 2020, thus credit will be available in August, 2020

*Even if invoice is not reflected in GSRT 2B for any month due to any reason such as non-filing of return by the supplier, supplier is liable to file quarterly return etc, Tax-payer can still take to the input tax credit subject to the maximum variance of 10%.

Importance and Benefit of GSTR 2B

Following are the major benefit of GSTR 2B:

  • It will help taxpayer in reconciling ITC conveniently with their books of account.
  • It will help taxpayer in reduction in time taken for preparing return and minimising error as ITC data will be auto populated in GSTR 3B.
  • It will help in ensuring that the ITC has not been taken twice or missed it.
  • It will help in computing ineligible ITC.
  • It will help in taking appropriate credit on import of goods including goods imported from SEZ.
  • It helps it payment of liability under reverse charge.

Content of GSRT 2B

The contents of GSTR-2B are as under:

  • GSTR-2B provides details eligible and ineligible Input Tax Credit (ITC) for each month.
  • GSTR 2B reflected Invoice wise detail of ITC.
  • Document wise details such as invoices, credit notes, debit notes, etc. to view and download.
  • It provides supplier wise summary and Input tax summary.
  • It provides summary statement showing ITC available and non-available for every section.
  • Advisory for every section that clarifies the kind of action that taxpayers must take.
  • Import of goods and import from SEZ units

Difference in GSTR 2A and 2B

GSTR 2A and GSTR 2B can be compared as follows: –

Points of differentiation GSTR 2A GSTR 2B
Kind of Statement Progressive or dynamic, as this changes as and when the supplier uploads the documents. Static or constant, as the GSTR-2B for one month cannot be modified based on future operations of the supplier.
Utility Less useful as tracing the changes in data taken substantial time. Very useful in ITC reconciliations, and to identify compliant/non-compliant vendors.
Input Tax Credit on Import of Goods Does not carry these facts. Accommodates ITC on import of goods as obtained from ICEGATE system (available from GSTR-2B of August 2020 onwards).
Eligible/ineligible credit Does not provide such data It provides document wise detail in respect of eligible/ineligible credit.

Our Comments: –

GSTR 2B is a welcome move for taxpayers as it reduces hurdles in availment of Input Tax Credit and its reconciliation. It also provides law reference for availability and non-availability of Input Tax Credit. Thus, it substantially reduces non-compliance in taking incorrect credit. It also helps in tracing of vendors who are not complying laws (Non-filing of returns). Thus, tax-payer, it order to avoid its ITC loss, can push the vendor to file its return or in due course if required, change him.

Thus, in a nutshell, GSTR 2B will help in reduction in time taken for preparing return, reconciling data, minimising errors, following up with Vendors for return and simplify compliance relating to filing of return.

Author- CA Pankaj Jain, CA Kamal Jangid – Partner, DYP Jain and Company – Chartered Accountant

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