The process of preparing and filing of annual return in GSTR 9 for FY 2018-19 under GST has started and there have been a number of doubts arising as to how to reconcile the Input Tax Credit (ITC) under various tables pertaining to the FY 2018-19, because the GSTR 3B filed for 2018-19 contains rectifications for the FY 2017-18 also and there could be certain ITC excess/ short availed in GSTR 3B filed for FY 2018-19, which might have been rectified in the GSTR 3B for the period April 2019 to September 2019, whereas some rectifications might have been missed to be done till September 2019. These issues have arisen because the GSTR 3B once filed cannot be rectified and any correction if required needs to be done in subsequent returns within the time limit prescribed under Section 39 (9) and other relevant provisions as allowed vide Circular No. 26/26/2017-GST, dated 29-12-2017. Time limits of Section 16(4) and related judgements will also need to be considered, however, the implications and disclosure requirements on the disputed legal aspects or any sub-judice matters have not been factored in these case studies as they may remain subject to the facts of the case and the views and conclusions of the tax experts/ auditors handling such instances for their clients, being matters of professional decision and competence.

We all know that there are various types of issues arising in the reconciliation/ its presentation in the GSTR 9, especially because the monthly returns for FY 2018-19 contained rectifications pertaining to FY 2017-18, but there is no table/ column or part for mentioning the same for reconciliation in the GSTR 9 of FY 2018-19. This problem may arise while filing GSTR 9 for subsequent years also if and until the Forms remain unchanged. The issues relating to reconciliation of output tax liability and reporting in GSTR 9 for FY 2018-19 were discussed in the first part of our article published on 13-06-2020. Further, to understand how the Input Tax Credit can be dealt with under the relevant tables in GSTR 9, regarding the liability relating to FY 2018-19 along with the rectifications of preceding year and rectifications relating to FY 2018-19 done in the succeeding year, a few case studies presented as below may be helpful. However, the implications and reporting of the case studies under Table 8 have been excluded in this article for better understanding of the more relevant and important tables 6,7, 12 and 13. While studying these examples, it may be kept in mind that the numbers appearing under Table 6A and Table 9 (Tax Paid through ITC) are auto-populated and hence cannot be changed.

For the sake of simplicity in understanding, Case Study No I to VI, we have considered only one head of GST, without separate data under CGST, SGST and IGST. The real cases may need such break up but the same approach can be applied.

Case-I – Input Tax Credit short availed in FY 2017-18 later fully availed in FY 2018-19; and Input Tax Credit short availed in FY 2018-19 later fully availed during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
75
0
18-19
200
25
185
210
15
0
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
75
210-25 = 185
7
12
13
25
15
Case-II – Input Tax Credit short availed in FY 2017-18 later partly availed in FY 2018-19; Input Tax Credit short availed in FY 2018-19 later partly availed during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
75
5
18-19
200
20
165
185
15
20
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
75
185-20 = 165
7
12
13
20
15
Case-III- Input Tax Credit excess availed in FY 2017-18 later partly reversed/ reduced in FY 2018-19; Input Tax Credit excess availed in FY 2018-19 later partly reversed/ reduced during April to September 2019 (Assumed that no ITC Balance was available in Electronic Credit Ledger at the time of filing of GSTR 9 for FY 17-18 &FY 18-19)
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
120
-7
18-19
200
-13
230
217
-20
-10
TREATMENT IN RELEVANT TABLES OF GSTR 9
Note: Amount payable by DRC 03 shall be paid in cash
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
120
217 + 13 = 230
7
-7
-10
12
-13
-20
13
Case-IV – Input Tax Credit excess availed in FY 2017-18 later fully reversed/ reduced in FY 2018-19; but Input Tax Credit excess availed in FY 2018-19 later partly reversed/ reduced during April to September 2019 (Assumed that ITC Balance was available in Electronic Credit Ledger at the time of filing of GSTR 9 for FY 18-19)
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
120
0
18-19
200
-20
230
210
-20
-10
TREATMENT IN RELEVANT TABLES OF GSTR 9
Note: Amount payable by DRC can be paid from balance available in electronic credit ledger subject to the condition that at least an amount of Rs. 10, i.e. amount payable through DRC 03 is continuously available in the electronic credit ledger since the date of filing of return for the month in which the ITC was excess availed till the date of filing DRC 03 against annual return, OTHERWISE the amount payable through DRC 03 to be paid in cash
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
120
210 + 20 = 230
7
0
-10
12
-20
-20
13
Case-V – Input Tax Credit short availed in FY 2017-18 later fully availed in FY 2018-19; Input Tax Credit excess availed in FY 2018-19 later partly reversed/ reduced during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
75
0
18-19
200
25
230
255
-20
-10
0
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
75
255 – 25 = 230
7
-10
12
-20
13
25
Case-VI – Input Tax Credit excess availed in FY 2017-18 later partly reversed/ reduced in FY 2018-19; Input Tax Credit short availed in FY 2018-19 later partly availed during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Acco-unts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
ITC could not be availed within Septe-mber 2019 to be written off in books subseq-uently
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
120
-7
18-19
200
-13
180
167
5
0
15
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
6B
120
167 + 13 = 180
7
-7
12
-13
13
5
Note: ITC of Rs 15 pertaining to FY 2018-19 could not be availed till September 2019 and hence cannot be availed later.
Case-VII – Input Tax Credit of CGST and SGST for FY 2018-19 availed as Input Tax Credit of IGST in FY 2018-19 by mistake; later rectified during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Accounts (FY 18-19) – Correct
GSTR 3B (FY 18-19) -Incorrect
Taxable value
IGST
CGST
SGST
Taxable value
IGST
CGST
SGST
18-19
100
9
9
100
18
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
IGST
CGST
SGST
6B
18
7
0
12
18 (Rectified in GSTR 3B return for the period April to September 2019)
13
9 (Rectified in GSTR 3B return for the period April to September 2019)
9 (Rectified in GSTR 3B return for the period April to September 2019)
Case-VIII – Input Tax Credit of CGST and SGST for FY 2018-19 availed as Input Tax Credit of IGST in FY 2018-19 by mistake; not rectified during April to September 2019
DETAILS OF INPUT TAX CREDIT
Fina-ncial Year
Books of Accounts (FY 18-19) – Correct
GSTR 3B (FY 18-19) -Incorrect
Taxable value
IGST
CGST
SGST
Taxable value
IGST
CGST
SGST
18-19
100
9
9
100
18
TREATMENT IN RELEVANT TABLES OF GSTR 9
Note: ITC for CGST Rs. 9 and SGST Rs. 9 could not be availed within September 2019 thus, it cannot be availed later; and has to be written off in books subsequently
Table
IGST
CGST
SGST
6B
18
7
18 (Not rectified in GSTR 3B return for the period April to September 2019, pay through DRC 03)
12
13

The above may help in preparing the GSTR 9 for FY 2018-19. There can be many more very complex situations which may need to be resolved and reported after proper reconciliation, however, the basic principles guiding the process shall remain the same. Any feedback/ suggestions/ difference in opinion with reasons to differ from experts are welcome.

We shall try to come out with another article soon with the impact and reporting of the above case studies in Table 8 in light of GSTR 2A, if readers find this one useful and worthy.

CA Raginee Goyal & CA Jewel GoyalAuthor: Article is jointly Authored by CA Raginee Goyal (Sr Partner) and CA Jewel Goyal (Partner) of Raginee Goyal & Associates.

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6 Comments

  1. RAMACHANDRA GUPTA says:

    Hello mam, Thank you for your posting on reconcilation and it is very useful and my problem is my client is doing both taxable and exempted goods but i have not reversed the common input under sec 42 till now and now i have to correct it in Gstr 9 if i have to show it in Table 7 under which head should i show whether under sec-42 or under other itc.

  2. Vinod Kumar Suthar says:

    Very good article. As you stated, you will come with new article Table 8 and GSTR-2A. Welcome.
    We highly needed reco. between table 8A and GSTR-2A.Thanks.

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