Introduction:
In this guide, we delve into the intricacies of filling out Table 4 for Input Tax Credit (ITC) in your GSTR-3B form without making any changes to the auto-populated figures from GSTR-2B. This topic has gained significant relevance in light of the recent rule changes and notifications, making it essential for taxpayers to ensure accurate reporting to avoid discrepancies.
GSTR-3B – TABLE 4 ITC HOW TO FILL ITC WITHOUT ANY CHANGE IN AUTO PUPOLATED FIGURES FROM GSTR-2B
The Government has introduced Rule 88D CGST Rules vide Notification No. 38/2023 – Central Tax applicable from 04-08-2023. By virtue of this notification the registered dealer shall be intimated through DRC-01C if there is difference between ITC available as per auto populated GSTR-2B and ITC availed by the registered person through GSTR-3B in a particular return.
To avoid such notice the Registered Person should be cautious to fill the table 4 pertaining to ITC of the return form GSTR-3B.
In this regard few changes have been notified in Table 4 of Form GSTR-3B for enabling taxpayers to report correct information regarding ITC availed, ITC reversal and ineligible ITC in Table 4 of GSTR-3B.
The New Electronic Credit Ledger “Electronic Credit Reversal and Re-claimed Statement” has been opened in the portal so that the Taxpayer may fill the unmatched entries in table 4.
The intention of the legislature that the taxpayer shall fill the table 4 (for ITC) in GSTR-3B without unchanged the auto populated figurers of GSTR-2B.
In this article we will discuss that how it will be possible that the ITC amount can be reported correctly without doing any changing in the auto populated figures
Auto populated figures in the table 4(A)(5) i.e. All Other ITC = Net ITC = (B2B Supplies – Credit Notes +/- B2B Amendments). The auto populated figures from GSTR-2B may be as under:
Supplies from registered persons other than reverse charge
B2B – Invoices
B2B – Debit notes
B2B – Invoices (Amendment)
B2B – Debit notes (Amendment)
Credit Notes
B2B – Credit notes
B2B – Credit notes (Amendment)
B2B – Credit notes (Reverse charge)
ITC available in GSTR-2B but not auto populated in table 4
ITC not available, on account of limitation of time period as delineated in sub-section (4) of section 16 of the CGST Act
or where the recipient of an intra-State supply is located in a different State / UT than that of place of supply.
Table 4 of GSTR-3B
| 4. Eligible ITC | ||||
| Details | IGST | CGST | SGST | CESS |
| A. ITC Available (whether in full or part) | ||||
| (1) Import of Goods | ||||
| (2) Import of Services | ||||
| (3) Inward supplies liable to reverse charge (other than 1 & 2 above) | ||||
| (4) Inward supplies from ISD | ||||
| (5) All other ITC | ||||
| B. ITC Reversed | ||||
| (1) As per rules 38,42 & 43 of CGST Rules and section 17(5) | ||||
| (2) Others | ||||
| C. Net ITC available (A-B) | ||||
| D. Other Details | ||||
| (1) ITC reclaimed which was reversed under Table 4(B)(2) in earlier tax period | ||||
| (2) Ineligible ITC under section 16(4) & ITC restricted due to PoS rules | ||||
We should know about the new electronic credit ledger opened from August 2023 i.e. “Electronic Credit Reversal and Re-claimed Statement (ECRARS)”. This ledger shall maintain the record of the ITC amount which has not been availed by the Taxpayer and such ITC amount shall be reclaimed at proper time when it should be availed according to the law.
Following Transactions may be required to be edit/rectify in the Table 4.
Tax Invoice – Tax Invoice Reported in GSTR-2B but goods not received during the relevant tax period.
Tax Invoice – Tax Invoice Reported in GSTR-2B but not pertaining to the Recipient
Tax Invoice – Valid Tax Invoice accounted for in Books of Account but not populated in the GSTR-2B
Tax Invoice – Tax Invoice Reported in GSTR-2B but it is pertaining to blocked ITC under section 17(5)
Tax Invoice – Tax Invoice Reported in GSTR-2B but not allowable due to provisions section 16(4) being applied or POS reason (such invoice amount shall not be auto populated in table 4)
Debit Note – Debit Note issued by the Recipient against purchase return but corresponding credit note has not been reported in GSTR-2B
Credit Note – Credit Note reported in GSTR-2B but not pertaining to the Recipient
Where to report the above transactions in Table 4 GSTR-3B and what additional action to be taken by the Taxpayer are explained as under:
| S.No. | Transaction | Transaction where it should be reported in Table |
| 1 | Tax Invoice Reported in GSTR-2B but goods not received during the relevant tax period. |
|
| 2 | Tax Invoice as per S.No.1 claimed in next Tax Period |
|
| 3 | Valid Tax Invoice accounted for in Books of Account but not populated in the GSTR-2B |
|
| 4 | Tax Invoice Reported in GSTR-2B but not pertaining to the Recipient |
|
| 5 | Tax Invoice as per S.No.4 amended by the Supplier in next tax period. |
|
| 6 | Tax Invoice Reported in GSTR-2B but it is pertaining to blocked ITC under section 17(5) |
|
| 7 | Tax Invoice Reported in GSTR-2B but not allowable due to provisions section 16(4) being applied or POS reason (such invoice amount shall not be auto populated in table 4) |
|
| 8 | Debit Note issued by the Recipient against purchase return but corresponding credit note has not been reported in GSTR-2B |
|
| 8 | Credit Note reported in GSTR-2B but not pertaining to the Recipient. |
|
| 9 | Credit Note as stated in S.No.8 amended by the Supplier |
|
Electronic Credit Reversal and Re-claimed Statement – This ledger shall inform that amount which the Tax Payer has reversed temporary through Table 4(B)(2). This temporary reversal may be availed in subsequent tax periods when condition for availing the ITC has been fulfilled. Such temporary reversal may be happened on account of following transactions:
ITC populated in GSTR-2B but conditions for availing the ITC stipulated in section 16(2) are not fulfilled.
ITC reversed under section 16(4) CGST i.e. payment was not made within 180 days.
When the Tax Payer shall avail such ITC report in Table 4(A)(5) and Table 4(D)(1).
Such type of pending ITC yet to be reclaimed (Accumulated unclaimed ITC balance in the books) shall be reported by the Taxpayer as opening balance by 30-11-2023.
If any mistake is done while reporting the opening balance the mistake can be rectified. Maximum three chance shall be available to the Taxpayer to rectify such mistake. The mistake can be rectified maximum by 31-12-2023.
Illustration for Electronic Credit Reversal and Re-claimed Statement
| Date | Particulars | Debit | Credit | Balance Credit |
| 01-11-23 | Opening | 10000.00 | 10000.00 | |
| 20-11-23 | Table 4(B)(2) | 5000.00 | 15000.00 | |
| 20-12-23 | Table 4(A)(5) and Table 4(D)(1) | 8000.00 | 7000.00 | |
| 24-12-23 | Mistake Rectify in Opening Balance | 2000.00 | 5000.00 | |
| 31-12-23 | Mistake Rectify in Opening Balance | 500.00 | 5500.00 |
Conclusion:
Accurate reporting of ITC in Table 4 of GSTR-3B is crucial to maintain compliance and avoid discrepancies. With recent rule changes and the introduction of the “Electronic Credit Reversal and Re-claimed Statement,” taxpayers need to be diligent in their reporting. By adhering to the guidelines and understanding where and how to report various transactions, taxpayers can ensure accurate and compliant tax reporting.
This article has been written without doing practical against transactions stated above. If any reader finds any discrepancy after applying any of the above stated directions or want to give any suggestion, he may email at pkmgstupdate@gmail.com.
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