Treatment of ITC reversed (4B2 of GSTR3B) and reclaimed (4D1 of GSTR3B) amount in GSTR-9, Goods and Services Tax - GST

[Ashish Gupta]

How to show the amounts of ITC reversed and reclaimed in GSTR-3B in Annual Return GSTR-9 ?

Should we show the reclaimed amount in column 6M of GSTR-9 and reversed amount in column 7H of GSTR-9 or is there any other method ?

Posts / Replies

[Padmanathan Kollengode]

What was the reason for reversal and reclaiming? was it because of non-payment within 180 days?

[Ashish Gupta]

Reversal and reclaimed was done because goods were received in next month i.e. Invoice was raised in 1st month and goods were received in next month.

[GUNASEKARAN K]

The reclaimed ITC should be shown in Column 6H of GSTR-9 and show the reversal in Column 7H

[Ashish Gupta]

If we put in 6H then there will be an error in Table 8. The value will be excessively negative. This can be avoided if we put in 6m

[Padmanathan Kollengode]

Ld Ashish Ji,

Negative Balance in 8D doesnot mean error per se. In your case, the negative balance should be reconciling with reversal in 7.

I do not think 6M is the right table because as per instructions, it is for credit taken in ITC-01 etc

[Ashish Gupta]

A lot of DRC are issued only because of negative Table 8 of GSTR-9. The heading of column 6M is "Any other ITC availed but not specified above". Can instructions be used as legal defence.

[Padmanathan Kollengode]

In my view, instruction is part of the form and unless it is contrary to the provisions of the Act or rules, i do not see any reason why one should simply ignore it.

Even if the instructions are to be ignored, kindly note that Table 6H provides for "Amount of ITC reclaimed (other than B above) under the provisions of the Act" which specifically provides for your case.

Since there is a specific column, I am of the view that declaring in 6M "Any other ITC availed but not specified above" is not proper.

Nevertheless, I do not personally feel that department sending notices based on Table 8D difference is a valid enough reason to make an incorrect declaration. If at all any notice has been received, such notice can easily defended based on declaration in 6H and 7 of GSTR-9 itself.

However, it is a personal call that one has to take.

[Padmanathan Kollengode]

Pls note that validity of reversal and reclaim for goods received in subsequent month based on the circular is all together a different issue and since the discussion is on disclosure, it is presumed to be done in accordance with the provisions of the Act.

[Sanjay Lakhotia]

Dear All,

Is there any update on this?

@Padmanathan ji, even Table 6H is not for that type of ITC reversal and reclaim. Table 6H is for ITC reversed and reclaimed due to non-payment to vendor within 180 days.

& yes, in recent cases, taxpayer got notices just because of negative figures in table 8D.

So to avoid these notices, can anybody help with the concrete answer.

[Padmanathan KV]

Sanjay Ji,

What is your suggestion in this regard? Which column to be filled?

[Sanjay Lakhotia]

I am also confused like others. To some extent I agree with Ashish ji. To avoid negative figures in table 8, the same can be shown in table 6M but at the same time, as per instructions / technical guide on GSTR-9 by ICAI, table 6M covers only those ITC which are directly populated to ECL From GST ITC-01/ ITC-03.

I don't want any negative figures in table 8 just because of change in reporting due to GST advisory dt. 02.09.2022, however at the same time, I don't want any wrong reporting in GSTR-9.

Hence, request you all to help on the said issue with your expert opinion.