Advisory on the Difference in Values Between Table
8A and Table 8C of Annual Returns for FY 2023-24
On December 9, 2024, the GSTN issued an advisory addressing
the concerns raised by taxpayers regarding the potential mismatch between the
values reported in Table 8A and Table 8C of the Annual Return (Form GSTR-9) for
the financial year 2023-24. This advisory was issued pursuant to the changes
brought in by Notification No. 12/2024-Central Tax (dated July 10, 2024)
and Notification No. 20/2024-Central Tax (dated October 8, 2024). These
notifications mandated that from FY 2023-24 onwards, the total credit available
for inward supplies would be auto-populated in Table 8A of Form GSTR-9 from
GSTR-2B of the respective financial year. However, Table 8C, which records ITC
for inward supplies of the current financial year but availed in the subsequent
financial year, must be filled manually by taxpayers.
This shift from using GSTR-2A in FY 2022-23 to GSTR-2B in FY
2023-24 for auto-population in Table 8A has resulted in some discrepancies. For
example, values in Table 8A for FY 2023-24 may be inflated due to the inclusion
of invoices from FY 2022-23 (reported late by suppliers). Conversely, values
for FY 2023-24 invoices reported late by suppliers and reflected in the GSTR-2B
of FY 2024-25 might be excluded, causing mismatches between Tables 8A and 8C.
To address these issues, the advisory provides clarity on
specific scenarios. First, invoices belonging to FY 2023-24 but reported by the
supplier after March 2024 will not appear in Table 8A. Such ITC must be
reported manually in Table 8C and Table 13 of GSTR-9 as it pertains to FY
2023-24. Similarly, if ITC for FY 2023-24 was reversed due to non-payment to
the supplier within 180 days and later reclaimed in FY 2024-25, this reclaimed
ITC should be reported in Table 6H of GSTR-9 for FY 2024-25 and excluded from
Tables 8C and 13 of FY 2023-24.
Another common issue arises when goods related to FY 2023-24
invoices are received late, resulting in ITC being claimed and reversed in
GSTR-3B as per Circular 170 and subsequently reclaimed in FY 2024-25. Such ITC
should be reported in both Table 8C and Table 13 of GSTR-9 for FY 2023-24.
However, invoices from FY 2022-23 that appear in Table 8A of FY 2023-24 due to
late reporting by suppliers should be excluded from Tables 8C and 13, as they
pertain to the previous financial year. This is in accordance with Instruction
No. 2A of GSTR-9, which specifies that Tables 4, 5, 6, and 7 should only
include details relevant to the current financial year.
Lastly, ITC that is claimed, reversed, and reclaimed within
the same financial year (FY 2023-24) must be reported in Table 6H or Table 6B,
but not both. As clarified in the CBIC’s press release dated July 3, 2019, this
information should not be duplicated in the reversal section (Table 7).
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Sr. No.
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Issue
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Reporting in GSTR 9
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1
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Invoice having the date of FY 23-24 but the
supplier has reported in the GSTR 1 after the due date of March’24. As a
result, this amount is not auto populated in the Table 8A of GSTR 9 for FY
2023-24 because it is the part of next years GSTR 2B. How to report such
transaction in the GSTR 9 of FY 23-24?
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Taxpayer shall report such ITC in the Table
8C and in Table 13 as this is the ITC of FY 2023-24. This is in line with the
instructions to the Table 8C and Table 13 of GSTR 9
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2
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Invoice belongs to FY 23-24 and ITC has been
claimed in FY 23-24. Due to payment not made to supplier within 180 days, ITC
was reversed in 23-24 as per the second proviso to section 16(2) and this ITC
is reclaimed in next Year FY 2024-25, after making the payment to supplier.
How to report such transaction in the GSTR 9 of FY 23-24?
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This reclaimed ITC shall be reported in the
table 6H of GSTR 9 for FY 24-25 hence not in the Table 8C and Table 13 of
GSTR 9 of FY 2023-24. This is in line with the Instruction to the Table 13
given in the Notified Form GSTR 9. Similar reporting is applicable for the
ITC reclaimed as per Rule 37A
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3
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Invoice belongs to FY 2023-24 but goods not
received in 23-24 therefore ITC is claimed in Table 4A5 of GSTR 3B and
reversed in Table 4B2 as per the guidelines of Circular 170 and such ITC
reclaimed in next FY 2024-25 till the specified time period. How to report
such transaction in the GSTR 9 of FY 23-24?
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Taxpayer shall report such reclaimed ITC in
the Table 8C and Table 13 as this is the ITC of FY 2023-24.
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4
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Invoice belongs to FY 22-23 which is
appearing in the Table 8A of GSTR 9 of FY 23-24 , as the supplier would have
reported the same in GSTR 1 after the due date of filing of GSTR-1 for the
tax period of March 23. How to report such transaction in the GSTR 9 of FY
23-24?
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This is the ITC of last year (2022-23) and
was auto populated in table 8A of GSTR-9 of FY 22-23. Hence, aforesaid value
need not to be reported in the table 8C and Table 13 of GSTR-9 for FY 23-24.
This is in line with the instruction no 2A given for the notified form GSTR 9
which states that Table 4,5,6 and Table 7 should have the details of current
FY only
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5
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Where to report the reclaim of ITC for an
Invoice which belongs to FY 2023-24, and which is claimed, reversed and
reclaimed in the same year?
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As already clarified by the CBIC press
release 3rd July 2019 in the para k, It may be noted that the label in Table
6H clearly states that information declared in Table 6H is exclusive of Table
6B. Therefore, information of such input tax credit is to be declared in one
of the rows only.
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Further, as the claim and reclaim is
reported only in one row therefore the same should not be reported in the
reversal under table 7 of GSTR 9 of FY 23-24.
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The advisory underscores the importance of proper reconciliation
of ITC data between GSTR-2B, GSTR-3B, and books of accounts. Taxpayers must
also exercise diligence while manually filling Tables 8C and 13 to ensure
accurate reporting and compliance. The changes introduced for FY 2023-24 aim to
enhance accuracy by aligning ITC reporting with GSTR-2B, but they also require
taxpayers to adapt to the new framework to avoid errors or mismatches. For
further assistance, taxpayers are encouraged to consult the CBIC guidelines or
contact GSTN support for specific queries.
Disclaimer: All the Information is based on the notification, circular and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.
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