Pt III

Details of ITC for the financial year

Description

Cess

1

6

6

Details of ITC availed during the financial year

Instructions-Table 6A

A

Total amount of input tax credit availed through FORM GSTR-3B (sum total of Table 4A of FORM GSTR-3B)

ITC availed on all inward supplies through GSTR 3B will be reflected here.

The amount punched in Table 4A of GSTR 3B will be reflected here.

ITC received from ISD will we reported here.

The transitional credit will be reported in table 6K and 6L.

This is a non-editable field.

Instructions-Table 6B

B

Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs)

Inputs

It shall also include the ITC on services received from SEZ.

The figures are required to be bifurcated into the ITC availed on:

– Inputs

– Input Services

– Capital Goods

Only amount of ITC is to be disclosed. Value of inward supplies neednt be reported here but will be handy while preparing table 14 of GSTR 9C.

ITC availed through table 4A of GSTR 3B and reversed through table 4B of GSTR 3B, will be included here.

Such bifurcation was not required to be reported in GSTR 3B, but the same is required in GSTR 9.

If the Registered Person has disclosed gross total ITC [including ineligible ITC u/s 17(5)] in Table 4A of GSTR 3B and reduced the ineligible ITC in Table 4B (2) of GSTR 3B, then he should disclose the gross total ITC [including ineligible ITC u/s 17(5)] in Table 6B of GSTR 9. The ineligible ITC u/s 17(5) would be disclosed in Table 7E of GSTR 9.

This Table should contain data which has been disclosed in GSTR 3B for the period July 2017 to March 2018. Therefore, there is no scope for revision / addition of data which is available in books of accounts but not disclosed in GSTR 3B.

Exclusions: Following nature of ITC not to be covered in this column:

ITC availed on tax paid under RCM.

Import of goods and services

ISD Credit

ITC reclaimed which was reversed on account of non-payment to the vendor within 180 days as per section 16(2) read with Rule 37.

ITC pertaining to financial period but availed in the GSTR-3B after end of financial year ( i.e. 2017-18 invoices on which IITC availed in 2018-19)

Comment: There could be difference between ITC availed in GSTR-3B and ITC as per books of account. Such difference would form part of reconciliation statement in GSTR-9C.

Capital Goods

Supplies only from unregistered person will be disclosed here whether tax paid under 9 (3) or 9 (4).

In addition to inward supplies under section 9(3), supplies taxable under section 9(4) gets get covered till October 12, 2017 only (N.N. 38/2017- CT(R)).

In other words, inward supplies for which self-invoicing is required is to be reported here.

Exclusion

Supplies on which ITC is availed in FY 2018-19, will be reported in Part V.

Supplies from registered person will be disclosed in table 6D.

Import of services, although leviable to reverse charge, will be reported in Table 6F.

In case the ITC is not availed, reporting in not required.

Supplies on which ITC is availed in FY 2018-19, will be reported in Part V.

Supplies only from registered person will be disclosed here.

inward supplies under section 9(3) will only get covered.

In case the ITC is not availed, reporting in not required.

Inward supplies of goods from SEZ would be reported here.

Only IGST will be reported, customs duty i.e. BCD, social welfare surcharge will not be reported.

ITC availed from July 2017 to March 2018 will be disclosed here.

ITC availed in 2018-19 in respect of bill of entry pertaining to FY 2017-18 will be reported in Part V.

Note: The Government has clarified vide press release dated 4.6.2019 that import of goods on which ITC have been availed (whether in 2017-18 or 2018-19) to be disclosed here. However, it is to be noted that if the ITC availed in 2018-19 is shown here, it would result in wrong disclosure of ITC as such credit was not available for utilisation for the FY 2017-18 which has to be suitably explained by auditor in GSTR-9C.

The details would be available in the table 4(A)(2) of GSTR-3B.

In case of services provided by SEZ to DTA, the tax is charged by the SEZ itself and hence such supplies do not get covered in the RCM.

Import of service means:

– Supplier- outside India

– Recipient- In India

– POS- India

Only eligible portion received from ISD is to be reported here.

The details would be available in the table 4(A)(4) of GSTR-3B

Ineligible credit received from ISD will not appear.

The figures should be reported after considering the effect of ISD credit notes.

The situation could arise where ITC, which was earlier reversed pursuant to section 16(2) r/w rule 37, on account of non-payment of ITC to the vendor, is reclaimed.

ITC reversed in 2017-18 but reclaimed in 18-19 will be reported in part V.

Ex:

– Total ITC availed during the period is Rs.1,00,000/-

– Less: The ITC reversed due to non-payment of value including tax to the supplier is Rs.20,000/-

– Add: The ITC reclaimed after payment made to the supplier is Rs.8,000/-

In this ex; the ITC to be disclosed in

– table 6B is Rs.92,000/-

– table 6H is Rs.8,000/-

– table 7A is Rs.12,000/- [20,000-8,000]

The difference in this column should be zero. However, in case the difference is in negative, the registered person has to identify the reason of such differences. If the difference is on account of excess availment of ITC for which no supporting exists, it may have to be paid through DRC-03.

Rule 39 :ITC reversed on account of ISD credit notes received.

Rule 42& Rule 43: ITC reversed on account of common inward supplies being used partly for business purposes and partly for non-business purposes, or partly used for making taxable supplies, including zero-rated supplies and partly for making exempt supplies.

Comment:

In case of Rule 42/43, there is requirement of reversal of ITC on monthly as well as on annual basis. This column should contain only such ITC which has been reversed in the monthly return.

There could be instances where the ITC reversed under these provisions is less than ITC required to be reversed or some ineligible ITC has been availed based on the invoice issued by ISD. There is no specific column for reversal of such ITC in the GSTR-9. In the absence of the same, there could be two approach to deal with the same:

1. The ITC in these columns may be shown net of ineligible ITC. This would result in difference between ITC availed as per GSTR-3B viz a vizfinal ITC to be taken in GSTR-9 which may have to be explained by the auditor in GSTR-9C.

2. Such excess credit may be reversed by disclosing it in the Table 7H of the GSTR-9.

In both the cases, the differential credit may be paid through DRC-03. There would be difference to that extent in Table 12 of GSTR-9C which could be explained by the auditor along with giving details of DRC-03 based on which such ITC has been reversed.

Normally, the registered persons do not include the ineligible credit in their GSTR-3B and hence this column should be nil. However, there could be instances where ITC is availed but it becomes ineligible subsequently (i.e. goods lost, stolen, destroyed etc). This Table should capture all such ITC which have been reversed by the registered person u/s 17 (5) of the Act.

– Table 4: Supplier registered under GST Law but the supplies made by them is liable under RCM for the recipient of supply

– Table 5: Credit Note/Debit Note issued by the supplier against original supply

– Table 6: Invoice issued by ISD based on which the ITC appears in GSTR-2A of the recipient entity

Out of above tables, only Table 3 and 5 (invoice issued by vendors and adjustment thereto on account of debit notes/credit notes issued) would only get reflected in this table.

ITC on import of services and on supplies under RCM is not considered here.

Table seeks at the comparison of ITC being reflected in GSTR 2A and the ITC availed in GSTR 3B.

There is no breakup available for the information auto populated in this table. The taxpayer is required to download GSTR-2A from common portal to examine the details as per Table 3 and 5 of GSTR-2A so that the break up can be compared with the ITC availed in GSTR-3B.

This would be same figure as reported in table 13 of GSTR 9other than ITC availed on RCM.

1. Inward supplies on which the ITC is blocked under section 17(5), or

2. Inward supplies not belonging to the registered person, or

3. ITC omitted to be availed.

4. Double reporting of the invoices by the vendor.

The above reason for differences is also required to be reported in table 8E and table 8F.

On the other hand, the negative figures would reflect the excess availment of ITC. It could be on account of:

1. Invoices not reported by the vendor in its GSTR 1.

2. Excess availment of ITC.

The appearance of negative figures would be matter of concern.

Table 8F covers instances of ineligible credits which could be on account of supplies covered under section 17 (5), vendors not pertaining to the registered persons or such other supplies which are appearing in the GSTR-2A but the registered person is not entitled to avail the ITC.

Further, as per the recent clarifications by CBIC, ITC on importsmade in 17-18, availed in 18-19 would also be reported here.

–  In case there is any difference in tax payable and tax already paid in GSTR 3B for the FY 17-18, the differential liability should be paid via Challan DRC-03.

–  The tax payable in this column should match with the tax payable as arrived at in the Table 4 of Part II of GSTR-9.

– System generated GSTR-9 is computing this amount based on the tax paid by utilising ITC as per GSTR-3B