GST law was supposed to Simply the Indirect Tax Practice & Compliance thereof. But the same seems to be nightmare. Annual GSTR 9 format introduced by GST Authorities has lot of complications being faced by Taxpayers & Tax Professionals. Government has recently given clarification on some issues, but a lot of clarifications are still awaited. Government in its Initial statement defined GST as Good & Simple Tax. But the same seems to be a very much complicated.

GST annual return filing is mandatory for all entities having GST registration, irrespective of turnover during the financial year. Hence, even businesses that have obtained GST registration and having even NIL turnover must file annual return. GST registration holder who has obtained the registration anytime before 1st April 2018 are required to file GST annual return for the financial year 2017-18 on or before 30th June 2019 in form GSTR 9. Thus all the registered entities has to file the same in the next Few Days only, after Due Date being extended for a very long span of Time.

When it comes to Tax Compliance, First question comes to mind of every Taxpayer that eligible ITC need to be availed in proper manner & should not be lapsed. Reporting of ITC in incorrect manner may bring hardship to Taxpayer. Few Issues being faced in general have been compiled & suggested Solutions & manner of reporting thereof has been discussed in this article.

There are 3 sets of Records available with registered entity :

  • Bills / Books of Accounts
  • GSTR 3B
  • GSTR 2A

There may be mismatch in the figures of ITC between these records & the same may consists of following:

Case 1 : No Mismatch

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)

5 5 5 5 5

5

Presentation in GSTR-9

GSTR 9 – Point 6B

IGST (Rs.) CGST (Rs.) SGST (Rs.)

5

5

Case 2 : Non Reporting of ITC in GSTR 2A

Bill not in GSTR 2A due to any reason like :

  • Counter-Party did not filed GSTR 1 yet
  • Counter-Party filed GSTR 1 with our Bill shown in B2C
  • Counter-Party filed GSTR 1 with our Bill shown with GSTN of other party
  • In GSTR 1 Counter Party wrongly clicked Composition tick on our Bill
  • Counter-Party filed GSTR 1 without our Bill etc

BILLS : 2017-18

GSTR 3B : 2017-18

GSTR 2A : 2017-18

IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
20 20

Presentation in GSTR-9

GSTR 9 – Point 6B

IGST (Rs.) CGST (Rs.) SGST (Rs.)
20

Case 3 : Reporting of ITC in GSTR 3B in next month within 2017-18

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
15 15 15** 15** 15

15

**Bill not in correct month in GSTR 3B in FY 2017-18, But shown next month in FY 2017-18

Presentation in GSTR-9

GSTR 9 – Point 6B

IGST (Rs.) CGST (Rs.) SGST (Rs.)
15

15

Case 4 : Reporting of ITC for 2017-18 in GSTR 3B in next year i.e. 2018-19

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
20 20 20

20

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8C & 13
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
20

20

Case 5 : Non-Reporting of ITC for 2017-18 in GSTR 3B till 31.03.2019 i.e. ITC Lapsed

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
25 25 25

25

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8E

IGST (Rs.)

CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
25

25

Case 6 : Excess-Reporting of ITC for 2017-18 in GSTR 3B (Rectified Same Year)

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
-**

** Wrongly Claimed Rs.60 ITC in July-17 GSTR-3B and Reversed the same in Sept-17 in GSTR 3B. Consequent effect in FY 2017-18 being Zero.

Presentation in GSTR-9

GSTR 9 – Point 6B
IGST (Rs.) CGST (Rs.) SGST (Rs.)

Case 7 : Excess-Reporting of ITC for 2017-18 in GSTR 3B (Rectified in FY 2018-19)

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
70

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Table 12
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
70

Case 8 : Excess-Reporting of ITC for 2017-18 in GSTR 3B (Not rectified till 31.03.19)

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
80

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Table 12
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)

Note: There is no actual Bill but ITC was wrongly availed in GSTR 3B. Hence need to pay now Rs.80 in DRC 03 with Interest.

Case 9 : Reporting of ITC for 2017-18 in GSTR 3B in next year i.e. 2018-19 (Bill not in GSTR 2A)

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
45 45

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8C & 13
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
45

45

Case 10 : Non-reporting of ITC for 2017-18 in GSTR 3B till 31.03.2019 i.e. ITC Lapsed

(Bill not in GSTR 2A)

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
50 50

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8E
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
50

50

Case 11 : Excess ITC not related to our company, wrongly shown by Counter Party in GSTR 2A

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
110

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8F
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
110

Case 12 : ITC is ineligible / blocked credit u/s. 17(5) in GSTR 2A

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
120 120

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8F
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
120

Case 13 : CGST – SGST wrongly shown as IGST in GSTR 3B, not rectified upto 31.03.19

i.e. Correct ITC lapsed & Wrong ITC availed not rectified

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
65 65 130 65

65

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8E
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
65

65

IGST Rs.130 i.e. wrong availment of ITC to be deposited in DRC 03

Case 14 : CGST – SGST wrongly shown as IGST in GSTR 3B, but rectified upto 31.03.18

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
70 70 -** 70 70 70

70

** Rs. 140 IGST Credit wrongly availed in July-17 but reversed in Dec-18, hence effect in 3B comes to Zero.

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8E
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
70 70

Case 15 : CGST – SGST wrongly shown as IGST in GSTR 3B, but rectified in FY 2018-19

BILLS : 2017-18

GSTR 3B : 2017-18 GSTR 2A : 2017-18
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
75 75 150 75

75

Presentation in GSTR-9

GSTR 9 – Point 6B

GSTR 9 – Point 8C & Table 13 GSTR 9 -Table 12
IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.) IGST (Rs.) CGST (Rs.) SGST (Rs.)
75 75 150

Information extracted for GSTR 9 from above Tables

Table IGST (Rs.) CGST (Rs.) SGST (Rs.) Value derived from
6A – ITC of 3B 450 90 90 Auto Populate from GSTR 3B
6B – Correct ITC of 3B 20 90 90
6J (Auto Difference) 430 0 0 Table of Question 70+80+130+150 (Case 7 + 8 + 13 +15) – ITC wrongly availed in 3B
8A – ITC of 2A 230 275 275 Auto Populate from GSTR 2A
8B – Correct ITC of 3B 20 90 90 Auto fetch from 6B
8C – ITC of 17-18 claimed in 18-19 0 140 140
8D – Difference 210 45 45 Auto fetch (Reason is 8E+8F + Difference of 8D-8E-8F)
8E – ITC not availed 0 140 140 Rs. 25+50+65 (Case 5,10 & 13)
8F- ITC not eligible 230 0 0 Rs. 110+120 (Case 11 & 12)
8D Minus 8E Minus 8F i.e. Not in GSTR 2A -20 -95 -95 IGST Rs.20 Case No.2 and CGST/SGST Rs.45+50 Bill 9 & Case 10 not in GSTR 2A
Table 12 – ITC Reversed in FY 2018-19 220 0 0 IGST Rs.70+150 (Case 7 & 15)
Table 13 – ITC Claimed in FY 2018-19 0 140 140 Equals to Table 8C
ITC as per Bills 20 370 370 8B + 8C + 8E
Payment to be done for

Un-rectified ITC availment (DRC 03)

210 0 0 Rs.80 Case No. 8 + Rs. 130 Case No.13

Please refer all the relevant section, rules, notifications and amendments as applicable. The Author is not responsible for any losses incurred. Content is merely for sharing knowledge & Educational Purpose only. Author can be reached at casagargambhir@gmail.com for any queries, issues & recommendations

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157 Comments

  1. AFSANA M Nadaf says:

    TRANS credit came auto populated in GSTR-9 for FY-18-19 and we have filed the same GSTR-9 .But no TRANS credit was actually claimed for FY-18-19 and it was not reflecting in Electronic credit ledger also.What is the effect as GTSR-9 and 9C is already filed
    Thank u in advance

    1. CA Sagar Gambhir says:

      There is no issue, as GSTR 9 & 9C don’t effect credit Ledger. Further this is GST website issue as it automatically populated data of tran credit. There won’t be any adverse view taken by the department

  2. SANDEEP LAKHANI says:

    one of my client has paid Less Tax in GSTR 3B for 2018-19 amounting to 16,39,645.90 and he has also Claimed less ITC in GSTR 3B of 2018-19 amounting to 16,07,140.06.
    Can he set off the same in annual return GSTR 9 and reverse the Balance Output tax due as 32505.84 vide DRC-03

  3. Nirali says:

    ITC of FY 17-18 forgotten to be claimed has been claimed in GSTR 3b of March 19 of 47000
    However, in GSTR 9 of FY 17-18, only 13000 has been mentioned..what should be done now?

  4. Radha Gopalakrishnan says:

    Sir I filed GSTR9 for 2018-19 with error. i.e.in table 6 of GSTR9 i have by mistake claimed excess SGST ITC credit. but ITC as per my 3B is correct which it is taking in table 9 of GSTR9. since by mistake i have claimed excess in table 6 of GSTR9, in GSTR9C it shows an un reconciled ITC. How to solve this problum

  5. M L Jain says:

    Our vendor has not deposited the GST collected from us and therefore GST availed as per gstr 3 b is higher than gst available as per gstr 2A. We have made payment and we are having the vendor bill also. Can we claim this ITC in annual return.If it can not be claimed than how to show this annual return for 18-19 keeping in mind that we have reversed such itc in return GSTR 3 B on proportionate basis (91% reversed) of exempt turnover to total turnover. Please guide how to reflect these in annual return

  6. kratika says:

    how to treat credit and debit notes in gstr9, isssued by our supplier in fy2018-19, reflecting in our 2A,for which no treatment is done from our side?

  7. RAJEEV says:

    Unclaimed ITC of 2017-2018 has been claimed in the GSTR 3B of the month of September 2018, but during filing of GSTR 9 of 2018-2019 the auto populated ITC as per 2A is excluding the ITC of 2017-2018. and the difference is coming. There is no such column in the GSTR 9 of 2018-2019 were I should give the detail’s of ITC of 2017-2018 which was availed in 2018-2019. Kindly help me

  8. NANDINI BARUA says:

    Dear Sir,
    I have one query, ITC AVAILED in Feb’2019 but in March 2020 it was noticed that the said ITC was not eligible and the same was never UTILISED. Can the same be REVERSED through GSTR-3B of March 2020 and what is the rate of interest.

  9. sanjay says:

    sir,
    One of my client failed to report/submit his 2 nos of supply invoices in FY2018-19. I took/claim the ITC for the same in my returns, but GSTR -2A never reflected. after repeated followup this client filed/submitted these invoices in feb2020. So my ITC available is more than what i claimed this year.
    My question is-
    1] How i can show/adjust in annual returns for 2018-19. OR i have to leave it.
    2] How to use this itc to set off my current liabilities.

    1. CA Sagar Gambhir says:

      You may present correct figures but rectification is not possible through GSTR 9 / 9C. As ITC can’t be availed or reversed through these forms.

  10. Harsh says:

    Sir,
    1. I have claimed excess ITC In 2017-18 and voluntarily paid through DRC 03 in August 19 where to show it in GSTR9 & 9C.

    2. I have claimed excess ITC In 2017-18 where to show it in GSTR9 & 9C.

    PLS HELP

  11. harish says:

    Credit notes have been paid tax in 3B instead of reducing the same from input. Now it is like sale is more in 3B then actual which is showing tax paid is more than payable, and Excess input is claimed as 2A is showing input net of credit notes.
    Actually there is no revenue loss to department but people suggesting to reverse ITC with interest and claim Refund for excess paid which is a trouble some process and interest is to be paid even though no tax evasion. Any alternative to deal with this in GSTR 9 and 9C

    1. CA Sagar Gambhir says:

      You may present correct figures but rectification is not possible through GSTR 9 / 9C. As ITC can’t be availed or reversed through these forms.

  12. Iyshvarya says:

    Sir , Thank you for your very valuable guidance.
    During 17-18, we had ‘import of goods’ for which 5 lacs IGST was paid. But in 3B, Igst input availed was 6 lacs. The excess 1 lac input availed is not reversed yet. We are going to pay this 1 lac through DRC 03.
    Q1 – In 6E, should i put 5 lacs or 6 lacs.
    Q2 – In 8G, should i put 5 lacs or 6 lacs.
    Q3 – Should i mention this 1 lac in table 7.
    Thank you very much in advance

  13. palak agrawal says:

    Sir, I have claimed excess ITC in 2017-18 by Rs. 50000 but I’ve rectified the same by reducing the itc of 2018-19 by Rs.50000 but i’ve not shown the same separately as itc reversed in 3b. how to deal with this in GSTR 9?

  14. Purnima Ambawat says:

    In case of excess ITC claimed thru 3B,how to reverse in GSTR9 for 17-18,. Whether to enter in Table 7h or table 12. Whether additional liability for tax and interest can be added in Table 9

    1. CA Sagar Gambhir says:

      Purpose of Table 12 is for presentation of any reversals relating to FY 17-18, but reversed in 3B of FY 18-19. (availed in 17-18 , reversed in 18-19)

      In case ITC for FY 17-18 availed in 3B, but was liable for reversal , , still not reversed , then
      1. Show such ITC in 6M : any other ITC availed (not in 6B Breakup) and
      2. In 7H (other reversal) and
      3. Increase Tax payable in Table 9, pay through DRC 03.

      Yes, additional Liability need to increase in Table 9 i.e. Tax Payable.

  15. SHITAL SHAH says:

    Dear Sir,
    I have wrongly add igst of 11700.00 in my GSTR3B of july2017 return but never USED IT & reverse it in GSTR3B OF july2018 return.
    my question is that where should i show this in GSTR9 return & should i have to pay interest on this which is never been used? please clarify this.

  16. Gourav says:

    Dear Sir we have excess taken ITC in 2017-18 in CGST Rs 7,696 and SGST Rs 7,696. and after that we rectify the same by reversal in 2018-19 in SGST Head Rs 15392.
    how to shown in annual return ?
    is the 7696 and 7696 to be include in table 6B

  17. Mufaddal says:

    Thank you sir for sharing this, It was a lot helpful
    Please help me figure out the following:-
    I am stuck in a case where ITC is being availed but not utilised for FY 17-18 and is not reversed till Dec 19, which gives 2 questions
    A. For how much period Interest to be calculated?
    B. what is the treatment of unutilised credit in electronic credit ledger? since Dealer is indulged in Exempt outward supplies.

    1. CA Sagar Gambhir says:

      1. From the Month of Availment to the month of Reversal : Interest
      2. In case of Exempt Sales, ITC is not to be availed & hence reversal to be done

  18. Mufaddal says:

    Sir, It was very helpful, Thanks a lot for sharing this.
    I am stuck with another problem that ITC mistakenly availed but not utilised is not reversed till date, I have 2 questions:
    A. For how much period Interest will be calculated.
    B. What to be done with balance in credit ledger, since it is still not utilised.
    Will you please help me figure it out.

    1. CA Sagar Gambhir says:

      1. From the Month of Availment to the month of Reversal : Interest
      2. In case of Exempt Sales, ITC is not to be availed & hence reversal to be done

  19. aadhar says:

    ITC OF APRIL-18, WRONGLY CLAIM IN MARCH-18.

    NOW SAME IS REFLECTING IN GSTR-2A OF FY 18-19 BUT ITC CLAIM IN FY 17-18.

    HOW CAN WE CORRECT THE SAME IN GSTR-9 OF FY 17-18

  20. Rakhi says:

    excess ITC was claimed in the year 217-18 which was wrong. how to rectify in annual return? and 18% interest from which date i will calculate? plz expain

  21. Preeti says:

    Dear Sir,

    another query is I have shown Input Credit in Return in FY 17-18 But the same is not shown in the accounting book of FY17-18. It has been shown in FY 18-19. CASE 8 solution will increase my interest liabilities. How to show this ?

  22. Preeti says:

    Dear Sir,

    I have taken the excess INPUT GST Credit and same is reversed in the same year within FY 2017-2018. but GST3B auto populated data is showing the total input amount without reversal of excess credit. How to show that figure in GST.
    for Example it was a totaling mistake Rs. 100 IGST has been taken instead of Rs. 90 in Feb18. Extra Rs. 10 has been reversed in Mar18 Month. but in autopopulated GST3B Data its showing Rs. 100 IGST.
    how to rectify the same in GST 9.
    I was looking at the CASE 6 but its not resolving my issue.
    by the way thanks a lot for providing such easy step by step solutions for us 🙂

  23. Shiv Kumar says:

    Dear Sir,
    I have filed GSTR 9. ITC in 2A less than 3B.
    I want to reverse the ITC using DRC 03.
    Can I reverse the ITC using Electronic Credit Ledger or I have to reverse the ITC from Cash legder only.

    Thanks in advance!!

  24. Nitin N Bhatt says:

    Sir During July 2017, in GSTR3B my available ITC was Rs 55500 (SGST) & 55500(CGST), but it was first return and instead of SGST I put 55500 as IGST, and I forget to adjust up to Mar-2019 return, now in GSTR 9 SGST is my liability of Rs 55500, so can I adjust its in my GSTR 9, or that amount is my loss? please answer me for same

  25. prachi says:

    Dear Sir,
    we have wrongly entered the excess itc in the year 2017-18 and we reversed the itc in the year 2019-20 so how to show in the annual return of the 2017-18

    1. sarayu says:

      Sir, I have remitted RCM on GTA partially in 17-18, and partially in 2018-19 and still some difference is there to be paid. where shall i show these figures..?

  26. Vikash Agarwal says:

    Hello Sir, my query is regarding Case No. 6 & 7 of your article. 1) In Case No. 6, if Excess ITC is taken in 3B & reversed during the FY-17-18 itself then your presentation suggests that i should take nothing in Point No. 6B, & nothing in Point No. 7. Is that Valid if i have taken gross figures in Table No. 4(A) Point No. 5 of GSTR 3B & then reversed in next month in Table No. 4B of GSTR3B i.e. reversed through amount shown in Other reversals or is that hold good only in case when i reduced my gross itc in next month Table 4a(5) of GSTR3B & shown nothing under reversals

  27. Abhishek Rajput says:

    Dear Sir,

    I have a query that is my counter party is showing my bill in GSTR-2A but that bill not reflecting in GSTR-9 column no.8(A) ITC as per GSTR-2A.

    So, Please suggest me what should i do?

    1. CA Sagar Gambhir says:

      Figures in Table 8A of FORM GSTR-9 are auto-populated only for those FORM GSTR-1 which were furnished by the corresponding suppliers by the due date. Thus, ITC on supplies made during the financial year 2017-18, if reported beyond the said date by the corresponding supplier, will not get auto-populated in said Table 8A.

      It may also be noted that FORM GSTR-2A continues to be auto-populated on the basis of the corresponding FORM GSTR-1 furnished by suppliers even after the due date. In such cases there would be a mis-match between the updated FORM GSTR-2A and the auto-populated information in Table 8A. It is important to note that Table 8A of the annual returns is auto populated from FORM GSTR-2A as on 1st May, 2019.

  28. Priya Jain says:

    I have availed ITC in 3B in 17-18 and the seller have shown in B2C so it is not showing in my 2A.
    In 18-19 neither seller has rectified nor I has reclaimed the itc.
    now in gstr 9 i want to reverse such itc so where to disclose.

    1. CA Sagar Gambhir says:

      As per clarification of GST Department,

      “ITC can’t be availed or reversed through Annual Return:
      No input tax credit can be reversed or availed through the annual return. If taxpayers find themselves liable for reversing any input tax credit, they may do the same through FORM GST DRC-03 separately. Thus, GSTR 9 don’t have any impact on Credit Ledger.”

      Thus, you may should only correct ITC in Table 6B i.e. Inward supplies (other than imports and inward supplies liable to

      reverse charge but includes services received from SEZs)

      and Wrong excess amount in Table 6M “Any other ITC availed but not specified above”

      and reverse the same through DRC 03. (also increase Tax Payable in Table 9).

  29. Nagarjuna says:

    Dear sir
    Q1.There is RCM purchases for the F.Y.2017-18 and we are not Aviled ITC as well as paid GST on such RCM transactions and how can we treat in GSTR-9/9C . If it is to be considered in GSTR-9/9C and is it liable to pay Interest along with Interest @24% or 18%

    Q2. Some Purchase returns are wrongly Considered as Sales in GSTR-3B and tax paid accordingly and we want to show it as Original Purchase Returns in 9C. Is it liable to pay Interest@24% when we will rectify in GSTR-9C.

    Thanks in Advance

  30. MLN SURESH KUMAR says:

    Sir,
    What is the “present option” available for mistake done by our supplier (i.e wrong GST No. filed ,Not ours, due to that unable to reflect in GSTR2A for FY 2017-18) for which we have to loose ITC?

  31. Saksham Garg says:

    Dear Sagar Ji,

    Nice Post

    I made some unregistered purchase in July 2017, the GST on these purchases needs to be deposited under Reverse Charge Mechanism but due to some error we forgot to pay this.

    In the return of August 2017 we have taken ITC of above reverse charge by assuming that we had paid the reverse charge GST in month of July 2017.

    Now i will pay the reverse charge GST with interest through DRC-03 but what will be the treatment of ITC claimed of reverse charge which was actually not paid at that time?

  32. Himanshu says:

    During the year change composition from regular but itc 03 form not filed….. Can i reversed of itc through drc 03 form in annual return

    1. CA Sagar Gambhir says:

      As per clarification of GST Department,

      “ITC can’t be availed or reversed through Annual Return:
      No input tax credit can be reversed or availed through the annual return. If taxpayers find themselves liable for reversing any input tax credit, they may do the same through FORM GST DRC-03 separately. Thus, GSTR 9 don’t have any impact on Credit Ledger.”

      Thus, you may should only correct ITC in Table 6B i.e. Inward supplies (other than imports and inward supplies liable to

      reverse charge but includes services received from SEZs)

      and Wrong excess amount in Table 6M “Any other ITC availed but not specified above”

      and reverse the same through DRC 03. (also increase Tax Payable in Table 9).

  33. Dharmin Shah says:

    Hi Sir,
    As per gstr 3b tax showed as 6 lacs and as per gstr 2A it shows as 4.5 lac…supplier didnt filed the gstr1…because of this..differebce arisez..if client dont want to pay the differnce..what is the other resolution…

  34. MATHEWB P M says:

    Dear sir,
    Great work, thank you very much. Sir would you clear my doubt is Excess Input claimed in GSTR 3B in 17-18 but not availed till date.No corrections made. Can I rectify this in GSTR 9. Awaiting your valuable reply

    1. CA Sagar Gambhir says:

      Point no.3 of press release

      No input tax credit can be reversed or availed through the annual return. If taxpayers find themselves liable for reversing any input tax credit, they may do the same through FORM GST DRC-03 separately. Thus, GSTR 9 don’t have any impact on Credit Ledger.

  35. bpjain says:

    dear sir, i claimed itc under wrong head in 2017-2018 and reverse the same in 2018-2019 and paid some
    amount through drc-03.and not paid int.please advice me should i pay int. and where to show this amount of drc-03 in gstr-9
    with thanks

  36. K.L. Gupta says:

    One Reverse Charge entry wrongly mentioned in GSTR-3B ( table 3.1(d)) in the month of Sept, 2017 and accordingly excess taxes paid in the same month. However, this excess paid taxes claimed in subsequent months by showing more ITC on purchases. How same can now be rectified in GSTR-9 for 2017-18.

  37. Kewepu says:

    Dear sir I have a couple of query’s. I would be very greatful if you could kindly answer them. I have made wrong payment of tax and claim excess ITC for 2017-18. No amendment made so far. Is it possible to rectify this mistakes in GSTR 9.

  38. Chaithra Ramesh says:

    Dear Sir,
    “ITC on inter-state purchases” are wrongly shown under “Imports of Services” while filing GSTR-3B. (Wrong Bifurcation among ITC details).

    GSTR-9 is showing up only the figures of ” All other ITC” column than The “Net ITC available”. Should I reverse such ITC(wrongly bifurcated) in GSTR-9 and pay additional Tax liability in DRC-03?

  39. upendra shah says:

    itc not claimed in gstr 3b upto returns filed for upto march 2019 but claimed in the books of accounts and also reflected in GST2A and can be claimed in Annual return
    Is not the case ITC lapsed and payment is to be made?
    Please guide me

    1. CA Sagar Gambhir says:

      ITC for bills belonging to FY 2017-18 could be claimed in GSTR 3B Filed upto 31.03.2019. Additional ITC can’t be claimed in Annual Return. If additional Liability Tax impact , then need to pay through DRC 03

  40. MALLELA ANJANEYULU says:

    Sir, Rs.2,947.65 ps.(Positive Value) appears in Table No.8D of GSTR 9. I have arrived the following figures after reconciliation of the statement.
    1) Unclaimed ITC is Rs.3,573/-
    2) Bill not uploaded value is Rs.625.35 ps.
    3) Net Value is Rs.2,947.65ps.

    Now my doubt is which amount to be shown in 8E. If I show Rs.3,753/-, it will come Rs.3,753/- in 8K as against positive amount of Rs.2,947.65ps. in 8D. Please clarify the same.

  41. MALLELA ANJANEYULU says:

    Sir, Thank you for clearing my earlier doubt. Now my another query is …….. “I have found from GSTR 2A that the supplier has uploaded his invoice by reducing the Basic Value and tax thereon as against the Invoice issued to us. They have not issued any Credit Note or informed it to the Purchaser. I have taken ITC according to the bill and claimed. Now I would like to repay the excess claimed amount and therefore, please let me know the procedure to be adopted. This Client turnover is below Rs.2.00 crore.”

    1. CA Sagar Gambhir says:

      Show the differential excess amount in 6M (not in 6B) & 7H. Add tax payable in table 9.. pay through DRC 03 with interest

  42. MALLELA ANJANEYULU says:

    Sir, you have stated to mention IGST Liability in Table 10 and 14 of GSTR 9 against my query. In this regard, I wish to state that when I am trying to mention IGST Tax liability in Table No.10, Liability of IGST increases as I have already made amendment of IGST Tax in GSTR 1 of 2017-18 (Tax was paid in the year 2018-19) and it seems from GSTR 9 that the IGST Tax liability increases in Table 4K and decreases CGST and SGST in Table 4L of GSTR 9. Please look into the matter clarify my doubt.

  43. MALLELA ANJANEYULU says:

    Sir, I have paid CGST and SGST instead of IGST in 2017-18 GSTR 3B as well as shown in GSTR 1 (Correctly reported the Basic Value of Invoice). Later on, it was noticed and rectified the same through amendment in the same year i.e. 2017-18, but Tax (IGST) was not paid in the year 2017-18 and it was paid in the year 2018-19. Now my question is in which Table IGST payable and IGST paid amount in GSTR 9 and in other words, the correct procedure to be adopted for showing the same.

      1. MALLELA ANJANEYULU says:

        Sir, when I am trying to mention IGST Tax in Table No.10 of GSTR 9, Liability of IGST increases because I have already made amendment through GSTR 1 in the year 2017-18. It seems from GSTR 9 that IGST Tax increases in Table 4K and decreases CGST and SGST in Table 4L. Please look into the matter and clarify the same.

  44. MAYURI JYOTSNA says:

    Sir,

    MISMATCH BETWEEN GST 3B AND GST1

    I have done sales entry in 3b, but forgot to do entry in gst1, where to show in annual return?

  45. Anju says:

    Sir, in Case 2 above, what if I have a negative amount in 8. D. of GSTR 9 (Difference)? Can I still file my GSTR 9? What are the future consequences & rectifications, if any?

    1. CA Sagar Gambhir says:

      *Challenge to ITC denial due mismatch with GSTR 2A- Delhi High Court issued notice to UNION OF INDIA*

      Delhi HC issues notice in writ petition challenging Section 16(2)(c), second proviso to Section 16(2)(d) and proviso to Section 16(4) of Central Goods and Service Tax Act, 2017 (CGST Act); Validity of Section 43A(6) of CGST Act, which hasn’t been notified yet, is also being challenged; Petitioner’s contention is that the Department has been vested with all the powers to recover any revenue lost owing to non-payment of taxes by erring suppliers and credit cannot be denied to recipient for default on part of the supplier; Lists the matter on September 18 : Delhi HC

      The matter is being heard by Division Bench comprising of Justice Dr. S. Muralidhar and Justice Asha Menon.

      The Petitioner i.e. Bharti Telemedia Ltd. is engaged in providing Direct-To-Home satellite television broadcast services. Writ Petition has been filed challenging the legality and validity of Section 16(2)(c), second proviso to Section 16(2)(d) and proviso to Section 16(4) of the Central Goods and Service Tax Act, 2017. The Writ Petition also challenged the validity of Section 43A(6) of the Central Goods and Service Tax Act, 2017, which has not been notified until.

      Section 16(2)(c) of CGST Act, 2017 provides for a condition wherein the recipient would only be entitled to Input Tax Credit if the tax charged in respect of such supply has been actually paid by the Supplier. The second proviso to Section 16(2)(d) provides that the recipient shall add an amount of Input Tax Credit availed, along with interest to the output tax liability if the recipient fails to pay the invoice amount to the supplier within 180 days.

      Proviso to Section 16(4) extends the benefit of availment of ITC till the due date of furnishing of return under Section 39 for the month of March, 2019 in respect of certain invoices, only if the supplier for such supplies has uploaded the details of such invoices in its return under Section 37(1) for the month of March, 2019. Section 43A(6) of the CGST Act provides that the supplier and recipient shall be jointly and severally liable to pay tax or pay ITC availed in relation to outwards supplies for which the details have been furnished under sub-section (3) and (4) but returns thereof has not been furnished.

      The provisions have been challenged on the following grounds:

      Section 16(2)(c), proviso to Section 16(4) is violative to Article 14 of the Constitution of India;
      The Department has been vested with all the powers to recover any revenue lost owing to non-payment of taxes by erring suppliers;
      The credit cannot be denied to the recipient for the default on the part of supplier.

      Delhi HC has issued a notice to Union of India today and posted the matter on sept 18,2019 thats it.

    2. CA Sagar Gambhir says:

      Yes, You can file with difference. But at the time of assessment, if the ITC don’t satisfy all eligibility requirements, then you may have to reverse & pay interest

    1. CA Sagar Gambhir says:

      *Challenge to ITC denial due mismatch with GSTR 2A- Delhi High Court issued notice to UNION OF INDIA*

      Delhi HC issues notice in writ petition challenging Section 16(2)(c), second proviso to Section 16(2)(d) and proviso to Section 16(4) of Central Goods and Service Tax Act, 2017 (CGST Act); Validity of Section 43A(6) of CGST Act, which hasn’t been notified yet, is also being challenged; Petitioner’s contention is that the Department has been vested with all the powers to recover any revenue lost owing to non-payment of taxes by erring suppliers and credit cannot be denied to recipient for default on part of the supplier; Lists the matter on September 18 : Delhi HC

      The matter is being heard by Division Bench comprising of Justice Dr. S. Muralidhar and Justice Asha Menon.

      The Petitioner i.e. Bharti Telemedia Ltd. is engaged in providing Direct-To-Home satellite television broadcast services. Writ Petition has been filed challenging the legality and validity of Section 16(2)(c), second proviso to Section 16(2)(d) and proviso to Section 16(4) of the Central Goods and Service Tax Act, 2017. The Writ Petition also challenged the validity of Section 43A(6) of the Central Goods and Service Tax Act, 2017, which has not been notified until.

      Section 16(2)(c) of CGST Act, 2017 provides for a condition wherein the recipient would only be entitled to Input Tax Credit if the tax charged in respect of such supply has been actually paid by the Supplier. The second proviso to Section 16(2)(d) provides that the recipient shall add an amount of Input Tax Credit availed, along with interest to the output tax liability if the recipient fails to pay the invoice amount to the supplier within 180 days.

      Proviso to Section 16(4) extends the benefit of availment of ITC till the due date of furnishing of return under Section 39 for the month of March, 2019 in respect of certain invoices, only if the supplier for such supplies has uploaded the details of such invoices in its return under Section 37(1) for the month of March, 2019. Section 43A(6) of the CGST Act provides that the supplier and recipient shall be jointly and severally liable to pay tax or pay ITC availed in relation to outwards supplies for which the details have been furnished under sub-section (3) and (4) but returns thereof has not been furnished.

      The provisions have been challenged on the following grounds:

      Section 16(2)(c), proviso to Section 16(4) is violative to Article 14 of the Constitution of India;
      The Department has been vested with all the powers to recover any revenue lost owing to non-payment of taxes by erring suppliers;
      The credit cannot be denied to the recipient for the default on the part of supplier.

      Delhi HC has issued a notice to Union of India today and posted the matter on sept 18,2019 thats it.

  46. ANIL JAIN says:

    Dear sir, thanku so much for your valuable solutions, one question is ITC of IGST wrongly reported in 3B in 2017-18 but not claimed and reversed till date, now auto populated in table 6A of annual return, where to shown in Annual return for rectification.

  47. Sharfuddin says:

    Sir, Thanks for your valuable information
    We take service from “X” vendor in the month of Aug 17. We received invoice with GST (Our GST number not mentioned on invoice) but we utilized ITC for the same invoice in Aug 17 only. Now the invoice is not reflecting in GSTR2A.

    Now the query is, can we reverse the ITC…? We need to pay the amount…? Where to show this type of ITC while filing GSTR 9, In which Table and which column.

      1. Sharfuddin says:

        Sir, Thanks for your support.

        we take the service in Feb 2018, we received invoice In may 18 and we utilised credit in May 18 GSTR3B return, but the invoice is reflecting in GSTR2A in FEB 18..in this cash where should we show the details in GSTR9

  48. Om says:

    Dear Sir,
    in our case GSTR 2A is showing Rs. 50 lacs and ITC as per Table 8A (Auto populated) in GSTR 9 is showing Rs. 48 lacs.
    What option is available?

    1. CA Sagar Gambhir says:

      Issues reported in filing Form GSTR 9 by the taxpayers: Steps to be taken
      14/06/2019

      Taxpayers have reported some issues in filing their Form GSTR 9, which are clarified below:

      1. Some taxpayers have reported that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A. Please note that this may happen due to following reasons:

      a. 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.

      b. 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 30th April, 2019, will not get auto-populated in table 8A of Form GSTR-9.

      c. 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, if any. Suppose an invoice with taxable value of Rs 100/- with tax of Rs. 18/- was filed in Form GSTR-1 in the month of January, 2018 and same was amended to Rs 90 as taxable value in the month of March, 2018, then

      i. the Form GSTR-2A of January, 2018 will show ITC of Rs. 18

      ii. the Form GSTR-2A of March, 2018 will show ITC of Rs 16.20 &

      iii. the table 8A of Form GSTR-9 will contain ITC of Rs 16.20.

      d. 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. For example if a taxpayer of State A visits State B and stays in a hotel in State B, the tax paid by him to the hotel in State B will appear in his Form GSTR-2A, but the same will not be reflected in table 8A of Form GSTR-9.

      e. 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.

      2. While filing Form GSTR 9 ‘Proceed to File’ button will be enabled only if ‘Compute Liability’ is clicked. This button is meant for computation of late fees only. Please note Form GSTR 9 once filed cannot be revised.

      Thanking you,

      Team GSTN

  49. aslam says:

    DEAR SIR,
    ITC AVAILED/CLAIMED IN GSTR 3B AND REFLECTING IN GSTR9 TABLE 6 BUT NOT UTILIZED TILL MAY 2019 RETURN SINCE THERE IS NO OUTWARD SUPPLY TILL NOW.

    WHAT WILL BE THE LAST DATE FOR UTILIZING SUCH ITC?

  50. ANUJ khaitan says:

    In Case No-8 above whether the amount of Rs 80/-not required to reported under Table 7H(Other Reversals) as Table 7J talks about Net ITC available for utilisation as per GSTR-3B.

    Also can the payment for the above Rs 80/- be made through DRC-03 by utilising the ITC balance although interest to be paid in cash only.?

    And Last, What option to select while making the payment for the same through DRC-03 of not reflected in annual return?

    1. CA Sagar Gambhir says:

      Open Form DRC 03
      Cause of Payment : Annual Return
      Payment Date : Today’s Date
      Section : 73(5) Voluntary
      FY : 2017-18
      Have you made Payment : Yes
      Enter PRN : Payment Reference No. is written in electronic Cash ledger against every payment

    2. CA Sagar Gambhir says:

      As per law,Payment for DRC 03 for Annual Return to be done through Cash Ledger only. although GST portal allows to utilize Credit ledger as well

    3. CA Sagar Gambhir says:

      For this case, presentation could be done in two ways.
      Either reducing ITC in Table 6
      Or showing as reversal in Table 7

  51. Raman says:

    Sir, I have a question that I’ve made excess reversal of input in Fy 2018-19 so can I claim that excess portion in Gstr9? if so then where to show that adjustment in Gstr9

    1. CA Sagar Gambhir says:

      ITC can be availed through 3B only. ITC for FY 2017-18, could be claimed in 3B from July-17 to Mar-19 (as Extended by govt)

  52. Shweta says:

    URGENT, Kindly suggest.

    Hello Sir,

    Regarding RCM, I paid the taxes (on RCM basis) during the return filing period for FY 17-18 (Jul-Sep) for Office Rent amount, while filing the GSTR 3B for each corresponding month.

    However, I missed to Avail (or forgot to show), the Input tax credit on the same(tax amount that I paid), during the same Financial Year for same corresponding months.

    Hence, I availed the ITC on that RCM, in next FY, that is in 2018-19, while filing GSTR 3B returns for the month of Apr 2018.

    Now, the only query is, where to show this type of ITC while filing GSTR 9
    In which Table and which column or head.
    Kindly suggest

    Regards

  53. Varun Jain says:

    Dear Sir
    Are amendments in bills, related to FY 17-18, but done in 18-19 by the supplier taken into account while arriving at auto-populated figures of table 8A of GSTR-9C??

  54. satyam says:

    i have taken input in FY 2017-18 but the counter party did not file the return and His registration is also cancelled. hence it is not showing in gstr 2A what is the adjustment for the same?

    1. CA Sagar Gambhir says:

      Refer case 5 of article.. ITC not claimed in 3B upto 31.3.19 for FY 2017-18 get lapsed..to be shown in Point 8E of annual return

    1. CA Sagar Gambhir says:

      Basically, 8C is for calculation purpose i.e. Reconciling ITC with 2A and 13 is for presentation purpose only for matching ITC in Next Year.

  55. Santhoshi says:

    Reverse charge Rs.50000 shown in FY 18-19 related to FY 17-18. Tax paid on it Rs.2500 and ITC taken Rs.2500 in FY 18-19. Where to show these amounts in GSTR 9

    1. CA Sagar Gambhir says:

      Reporting of Liability of Tax of RCM should be done in Table 10 under Pt. V : Supplies / tax declared through Amendments (+) (net of debit notes) of GSTR 9.
      As Input of RCM is available only after payment, hence no reporting of the same in this Annual Return.

  56. Arvind Agarwal says:

    Very clear and elaborate article. However I need one clarification. In case wrong availment of ITC in 3B in 17-18 but later reversed in 18-19 in 3B and the excess availment was never utilised, because there is more than sufficient balance in Electronic credit ledger ,is there liability to pay interest

  57. Nikhil says:

    If ITC of F.Y. 17-18 did not taken in same year as well as in F.Y. 18-19 ? then how should be shown in GSTR -9 Form. ? Plz. answer

    1. CA Sagar Gambhir says:

      Refer case 5 of article.. ITC not claimed in 3B upto 31.3.19 for FY 2017-18 get lapsed..to be shown in Point 8E of annual return

  58. lalit mishra says:

    Dear sir since a regular you & taxguru is awaring to all for gstr’s radiculas problems.it’s very appreciable job by you.i am realy very thankful for this job. but at another I suspect why such as you professional doing this job free of charge from other professional.are you availing right cost for this job. if no, It is a noble work for the nation developmental. Very Very Thanks for your these noble work.

  59. ASHIS KUMAR GUHA says:

    i always read carefully of your publication and found very knowledgeable since from the dates when I registered with you and again thank you for the articles.

      1. Nikhil says:

        Dear Sir, thanks for information, but i want ask the question, if ITC did not taken in F.Y. 17-18 as well as
        in F.Y. 18-19 also. where should be those ITC to be recorded in GSTR 9 while filing up the form ?

        1. CA Sagar Gambhir says:

          Refer case 5 of article.. ITC not claimed in 3B upto 31.3.19 for FY 2017-18 get lapsed..to be shown in Point 8E of annual return

          1. Nitin N Bhatt says:

            Yes that I understand but my auditor is saying this amount is lapsed so you cant get this ITC as input, so you pay this amount and forget that 55500 SGST, is this right? because its unnecessary my loss of Rs 55500

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