Excess availment/ Mismatch of GST Input Tax Credit (ITC) claimed in GSTR 3B Vs appearing in GSTR 2A.

With almost two years into GST implementation, the Government is putting all efforts to attain two fold agenda of curbing tax evasion by ensuring compliance and to boost up revenue collection.

Recently, many taxpayers across the country have received SMS and emails from tax authorities (GST Jurisdictional office) with regard to excess availment of ITC in GSTR 3B with ITC auto populated in GSTR 2A.

If you have received any such notice or get any such notice in future, you may follow the below suggestions:

Discrepancy in ITC availed in GSTR 3B Suggestion by TaxMarvel
The Taxpayers who have availed excess ITC in form GSTR-3B (Domestic Purchases – All other ITC of GSTR 3B) from those which got auto populated in GSTR 2A (Filing GSTR-1 by the Suppliers), the Jurisdictional GST Department is issuing notices through SMS and E-mails. We suggest you to take following actions:

1. Verify the correctness of the figure sent to you by the Department.

2. In case of any discrepancy in figures notified to you, please reach out to Department for correcting the same.

3. In case of discrepancy write to department that you shall ask suppliers to comply.

4. In case of any discrepancy in ITC availed, ask the Suppliers to immediately file GSTR 1 by including the details of invoices raised on you.

5. You may design the below SOP to avoid any interest/ penalty for such mismatches :

• Periodically reconcile your Purchase Register with GSTR 2A i.e. monthly/quarterly.

• Identify the differences and take below action:

(i) Avail any credit of invoices not appearing in PR but filed by Supplier.

(ii) Notify Supplier for missing invoices in 2A

(iii) Take action on mismatches of tax amount, tax type or invoice No./date.

(iv) Also reconcile all Credit/Debit Notes issued by Supplier with those appearing in books.

• In case any Supplier is found to be non-compliant, we suggest to have discussion with them to file their returns. If they don’t comply within reasonable time period deduct the tax and interest exposure to cover your prospective losses.

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Qualification: CA in Practice
Company: TaxMarvel Consulting Services LLP
Location: Hyderabad, Telangana, IN
Member Since: 18 Feb 2019 | Total Posts: 33
Rohit is an Enterpreneur and has founder a consulting boutique firm - TaxMarvel Consulting Services LLP. View Full Profile

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16 Comments

  1. DINESH says:

    Hello Sir,
    As per gstr-2a monthly details itc of rs.89907 is showing and same claim in gstr-3b.but in gstr-9 in table no.8 rs.83290 itc auto populated. what is the reason behind this.

    1. fcsrohit says:

      Dear Sir,

      GSTN has issued a clarification. As per clarification, only invoices which are filed in returns are considered for GSTR 9. Invoices which are uploaded by supplied (in submit state) and return not filed is not considered for GSTR 9

      You may raise a grievance with GSTN with necessary supporting details to respond

      Regards

      Rohit

  2. Sathya Components Centre says:

    Hello Sir,

    We have not claimed IGST in 3B during Jan 2019. However our supplier has uploaded and it is avabilable in 2A. How how do claim this.

    Thanks,
    Ramesh

    1. fcsrohit says:

      Dear Sir,

      You may claim ITC in next GSTR 3B. However, please check if the invoice is available with you, you have received the goods/services and it is appearing in your purchases.

      Regards

      Rohit

  3. K V JAYARAMAN says:

    we have valid supplier invoice during july 17 and 100% payment along with GST issued to supplier. but supplier omitted invoice in their GSTR 1. so far not rectified and not reflected in GSTR2A till date.
    we have claimed ITC as per invoice. shall we reverse ITC that not filed by supplier. pls clarify

  4. senthil says:

    GST, Just means out as Confusion and work load over and over. How it is possible to all to respond to Department and confirm the same. It is head ache to Department, Traders and Tax professionals. Already we are in GSTR 9 processing, meanwhile how this is possible. Government point of view is ok. But practically, fully head ache. Don’t mistake me for this view. I just explained the year long trouble in simple words. But we must train out to reach hassle free working arena.

  5. Pinakin Bhavsar says:

    Difference of IGST paid at the time of Import and taking as credit in 3B but not shown in 2A, what is end solutions to avoid notice from department.

    1. fcsrohit says:

      Hi Sir,

      IGST paid during imports does not form part of any discrepancy. Same is declared in a different table while filing GSTR 3B – Import of Goods. The notice is being issued for difference in ITC claimed in 3B – Table “All other ITC” and populated in GSTR 2A. Hence, you need not worry.

      You only need to reconcile all the IGST paid for imports and claim the same while filing GSTR 3B.

      Regards

      Rohit

  6. kurian koshy says:

    The difference may occur due to claiming of ITC in respect bills pertaining to previous year during the current year which has to be shown in the Annual return . Is is this correct?

    1. fcsrohit says:

      Hi Sir,

      Partially the statement is correct. But the department notice is due to difference in claiming ITC in GSTR 3B and those populated in GSTR 2A.

      If the difference is due to above reasons you may submit a reconciliation statement to the Department should you receive any notice

      Regards

      Rohit

  7. VIJESH SHAH says:

    THE MAJOR REASON FOR DIFFERENCE IS NON FILING OR INCORRECT FILING BY SUPPLIER LEADING TO GREAT HARASSMENT TO BUYER WHO HAS FILED HIS RETURN CORRECTLY. FOLLOWING UP SUPPLIER IS EXTRA BURDEN . PUNISHING BUYERS FOR FAULT OF SELLERS IS UNJUSTIFIED AND ILLEGAL

    1. fcsrohit says:

      Hi Sir,

      The provisions of Sec 16(4) is drafted in such way. Even though it may be little regressive but we need to comply with the provisions for availing ITC

      Regards

      Rohit

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