Friday, December 13, 2024

Checklist for Reporting Input Tax Credit (ITC) in GSTR-9 and GSTR-9C for FY 2023-24

This checklist ensures accurate reporting of Input Tax Credit (ITC) as per the latest updates and guidelines under the Goods and Services Tax (GST) framework for FY 2023-24. The details in Form GSTR-9 and Form GSTR-9C must reflect the correct ITC reporting, including scenarios of delayed reporting, reversal, and reconciliation, with special attention to Tables 8A, 8C, 6B, 6H, and 13.

Guidelines for Reporting ITC:

  • Auto-Population of ITC: Table 8A of GSTR-9 auto-populates ITC details from GSTR-2B. Review these details carefully for accuracy.
  • Manual Reporting: Table 8C requires manual reporting for ITC in certain cases, and Table 13 captures specific details, including ITC availed in subsequent periods. Be sure to follow the specific instructions for each scenario.

Common Scenarios with Reporting Guidelines:

  1. Scenario 1: Supplier Delays Reporting Invoice

    • Situation: Ashu receives an invoice on 10th February 2024, but the supplier files it in April 2024 in GSTR-1, leading it to appear in Ashu's GSTR-2B for FY 2024-25 instead of FY 2023-24.
    • Reporting Actions:
      • Table 8C: Report the ITC manually in FY 2023-24 (as the invoice pertains to this period).
      • Table 13: Include ITC availed in FY 2024-25 but attributable to FY 2023-24.
  2. Scenario 2: ITC Reversed Due to Non-Payment Within 180 Days

    • Situation: Ashu claims ITC of ₹50,000 in December 2023, but fails to make payment to the supplier within 180 days. The ITC is reversed in March 2024, and reclaimed in FY 2024-25 after payment is made in July 2024.
    • Reporting Actions:
      • Table 6H (FY 2024-25): Report the reclaimed ITC in the subsequent FY after payment.
      • Do Not Report in Table 8C or Table 13 (FY 2023-24): As the reversal occurs in FY 2024-25, do not include in FY 2023-24.
  3. Scenario 3: Goods Not Received in FY 2023-24

    • Situation: Ashu receives an invoice on 15th March 2024 but the goods are only received on 10th April 2024. Ashu claims ITC in March 2024 but reverses it in the same return, then reclaims it in May 2024 after receiving the goods.
    • Reporting Actions:
      • Table 8C: Report the ITC as belonging to FY 2023-24.
      • Table 13: Include ITC availed in FY 2024-25 for invoices related to FY 2023-24.
  4. Scenario 4: ITC of FY 2022-23 Appears in GSTR-9 for FY 2023-24

    • Situation: Ashu receives an invoice on 5th February 2023, but the supplier reports it late in May 2023, leading it to appear in Table 8A of GSTR-9 for FY 2023-24.
    • Reporting Actions:
      • Do Not Report in Table 8C or Table 13 (FY 2023-24): As the ITC belongs to FY 2022-23, it should have been reported in that year’s return. Ensure no duplication across periods.
  5. Scenario 5: ITC Claimed, Reversed, and Reclaimed Within FY 2023-24

    • Situation: Ashu claims ITC of ₹30,000 in January 2024, reverses it in February 2024, and reclaims it in March 2024 after resolving the issue.
    • Reporting Actions:
      • Table 6B or 6H: Report the ITC only once (either in 6B or 6H) per the CBIC Press Release (3rd July 2019). Avoid duplicating the reversal.
      • Table 7: Do not include the reversal in Table 7, as it has already been adjusted in the relevant row.

Table for Quick Reference:

ScenarioRelevant Table(s) in GSTR-9Additional Notes
Supplier Delays Reporting InvoiceTable 8C, Table 13Report ITC of FY 2023-24 in the subsequent FY section as manual entry.
ITC Reversed (180-day rule)Table 6H (FY 2024-25)Do not report in FY 2023-24. Report only in the subsequent FY after payment.
Goods Not Received in FY 2023-24Table 8C, Table 13Report ITC as belonging to FY 2023-24, but include in the next FY for actual availing.
Late ITC of FY 2022-23Do Not Report in Table 8C or Table 13Reported in FY 2022-23, ensure no duplication with FY 2023-24.
ITC Claimed, Reversed, and ReclaimedTable 6B or 6HReport ITC once; avoid showing reversal in Table 7.

Compliance Tips:

  • Manual Adjustments: Ensure that ITC in Table 8C and Table 13 is manually adjusted and reported accurately based on the scenario.
  • Avoid Duplication: Be vigilant to avoid duplicating the reporting of ITC in multiple tables for the same transaction.
  • Review GSTR-2B: Verify the auto-populated ITC details in Table 8A and ensure they match the actual inward supplies received during the financial year.
  • Follow GSTR-9 Instructions: Adhere to the instructions provided in Form GSTR-9 to prevent discrepancies and avoid penalties.