The Central Board of Indirect Taxes and Customs (CBIC) has issued an advisory to address concerns about discrepancies in Tables 8A and 8C of the Annual Return (GSTR-9) for FY 2023-24. The notification highlights key changes in reporting requirements and provides clarity on handling specific scenarios for input tax credit (ITC).

Key Changes and Background

  1. Auto-population from GSTR-2B: 

    • From FY 2023-24 onwards, Table 8A of GSTR-9 reflects ITC auto-populated from GSTR-2B instead of GSTR-2A, as per Notification No. 12/2024 and 20/2024.

    • Table 8C now requires taxpayers to manually report ITC on inward supplies availed in subsequent financial years.

  2. Possible Mismatches:

    • Since GSTR-2B reflects ITC based on the filing date of the supplier’s GSTR-1, delays or reporting adjustments can lead to inflated or reduced values in Table 8A, resulting in mismatches with Table 8C.

Common Scenarios and Reporting Guidance

  1. Invoice Date in FY 2023-24, but Reported Late by Supplier:

    • Issue: The supplier reports the invoice in GSTR-1 after March 2024, causing the ITC to appear in GSTR-2B of FY 2024-25.

    • Resolution: Report such ITC in Table 8C and Table 13 of GSTR-9 for FY 2023-24, as per instructions.

  2. ITC Reversal Due to Non-Payment to Supplier:

    • Issue: ITC is reversed in FY 2023-24 due to non-payment within 180 days but reclaimed in FY 2024-25 upon payment.

    • Resolution: Report reclaimed ITC in Table 6H of GSTR-9 for FY 2024-25. Do not include it in Tables 8C or 13 of FY 2023-24.

  3. Goods Received Late for FY 2023-24 Invoice:

    • Issue: ITC claimed and reversed in FY 2023-24 but reclaimed in FY 2024-25 upon receipt of goods.

    • Resolution: Report the reclaimed ITC in Tables 8C and 13 of GSTR-9 for FY 2023-24.

  4. Invoice from FY 2022-23 Appearing in FY 2023-24 GSTR-2B:

    • Issue: Supplier files GSTR-1 late, causing the invoice to appear in GSTR-2B of FY 2023-24.

    • Resolution: Do not report this ITC in Tables 8C or 13 of GSTR-9 for FY 2023-24. This ITC pertains to FY 2022-23 and should have been addressed in that year’s return.

  5. ITC Claimed, Reversed, and Reclaimed Within FY 2023-24:

    • Issue: ITC claimed, reversed, and reclaimed within the same financial year.

    • Resolution: Report such ITC only once, either in Table 6B or Table 6H of GSTR-9, as clarified in the CBIC press release of July 3, 2019. Avoid duplicating this information in Table 7.

Key Implications for Taxpayers

  • Clarity in Reporting: Taxpayers must carefully review their ITC claims and adjustments to ensure accurate reporting under the revised guidelines.

  • Reduced Mismatches: Following the prescribed methods will minimize discrepancies between Tables 8A and 8C, ensuring compliance and avoiding penalties.

  • ITC Timeline Management: Proper tracking of ITC across financial years is critical for seamless reporting under the ALMM framework.

By addressing these scenarios systematically, taxpayers can align with the new requirements and ensure a smooth GSTR-9 filing process for FY 2023-24.