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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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168 Comments

  1. Kiran Kumar says:

    Sir,
    if a Trader forget to fill 6B column (ITC) in GSTR9 and filed successfully for the F.Y 2021-22. Then what is the solution to file GSTR9C.

  2. Nikhitha says:

    Sir, ITC for the FY 2019-20 claimed in Sept’20 has been shown under 8C, but has not been disclosed in table 13 of the GSTR 9, will there be any problem in future?

  3. Mitali says:

    Sir,
    We have claimed total ITC correctly in GST3B for month of June 2019. But the classification between Imports and All other ITC has gone wrong. Import ITC is put under All other ITC while filing GSTR-3B for June. Which we realized while filing GST9- for 2019-20. Can we put the correct classification in Table 6E. If not what’s the correct course of action?

  4. Vijay says:

    I have claimed excess ITC in July-18 GSTR-3B for 2018-19. The same was revised in next month.
    So, the system generated annual GSTR-3B as follows:

    4(A)(5) – 100
    4(B)(2) – 20
    4(C) – 80

    In GSTR-9 I have mentioned as follows:

    6(B) – 100
    7(H) – 20

    But, 8(D) now shows negative value (-20), because 8(A) – 80 (net of reversal) and
    8(B) – 100 (includes the reversal).

    Is it correct? or should I mentioned the net ITC in 6(B) and leave 7(H) blank (as you described in case 6 above)?

    This is similar to the case 6 above. But you have mentioned the net value in 6(B) and not mentioned the reversal in 7(H). So, there is no negative value in 8(D).

  5. SHITAL SHAH 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. BECAUSE IN 2018-19 YOU CAN CLAIM ITC OF 2017-18 UPTO MARCH 2019Kindly help me

  6. SHITAL SHAH says:

    Unclaimed ITC of 2017-2018 has been claimed in the GSTR 3B of the month of MARCH 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 BECAUSE IN 2018-2019 IT IS UPTO MARCH2019 YOU CAN CLAIM ITC OF 2017-2018. Kindly help me

  7. Siddhanth jain says:

    Sir i filed GSTR 3B of one of my client. But while typing assessable value i forgot to take IGST and credit note amount. But tax amounts i have put correctly and GSTR 1 is filed correctly. So can i add that assessable value in the next month in GSTR 3B ??

  8. 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

  9. 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

  10. 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?

  11. 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

  12. 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

  13. 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?

  14. 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

  15. 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.

  16. 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.

  17. 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

  18. 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

  19. 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

  20. 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?

  21. 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

  22. 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.

  23. 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

  24. 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.

  25. 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.

  26. 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

  27. 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

  28. 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 ?

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