My self- Rajesh Deshpande from Pune Maharashtra working as a Manager-Finance in Pharmaceutical Company name of SAVA HEALTHCARE LTD. We would like to bring your kind attention towards current system of ITC availement and issues creating regarding at the time of reconciliation.
As you are fully aware that, GST2B is inserted on portal from Oct 20. Earlier assesse were doing the recon with GSTR2A.
Rule 36(4) as per CGST Act, has been applied and asked to assess to reconcile with your books and 2A, and if it is over ITC compared to 2A, assesse has to reverse the ITC.
R/Madam, earlier 2A and now 2B, reconciliation with Books every month, small assesse like us is a really facing trouble regarding this. GSTR2B is a Static statement but 2A is not, assesse can not refer a 2A for freezing of reconciliation with books, because it is change number of time as when tax payer amends it.
2B is freeze by portal on last date of GSTR1 at 12.00 pm and no further changes will be again reflecting in 2B after the month.
After considering the above duplication of work to reconcile the books and 2A, again and again we would like to suggest you the reconciliation with 2B and books as follows
Keep Caping on 1st Stage – i.e on 15th Oct – This will be 1st Recon part from April to Sept, and while keeping 15th Oct – those assesse will also cover who is filling Qtry returns, therefore till 15th Oct, actual ITC position will be clear. When assesse will do recon on 15th Oct, he has also strong proof to speak with vendor who has not filled return within a 6 month, during this period you can keep capping as usual of 10%, so ITC will be reverse which is not as per 2B/2A v/v books and assesse will SUMOTO reverse it.
Keep Capping on 2nd Stage – i.e on 15th May –Apply same procedure as per above and here almost 90% picture will be clear who is not filled GSTR1 and will be catch immediately. Assesse will reverse SUMOTO ITC this item also, those is not as per capping limit.
Keep capping on 3rd and Last stage-i.e 15th Oct ( Next FY-Prior to last date to avail ITC of previous year). This will be a final filter to avail or reverse the ITC as per Capping to assess.
Instead of 12 reconciliation with books, 2A AND 2B, if Govt keep only 3 reconciliation for the 1 financial to avail or reverse the ITC.
These 3 reconciliation can be used at the time of assessment by assesse and GST Officer. One more can do by Govt, that, assesse has to upload 6 Monthly reconciliation statement with along with the GSTR3B,
Considering to above points we request you to kindly think on it and take a suitable decision.