GSTR-3B is a crucial document as it provides a summary of GST output and Inputs to the government. In Table-4 of GSTR-3B, bifurcation is provided of Input Tax Credit availed by the taxpayer.
However, the government noted that in various cases taxpayers were making incorrect disclosures in Table 4 leading to false information to the government. Therefore, the government suggested various changes in Table-4 of GSTR-3B vide Notification No. 14/2022-Central Tax dated 5th July 2022 and clarified various disclosure-related issues vide Circular No. 170/02/2022-GST dated 6th July 2022.
Accordingly, various amendments are made in GSTR-3B with effect from 01.09.2022 and the following are the reporting scenarios in Table 4 of GSTR-3B with effect from 01.09.2022.
1. Updated Format of Table-4 of GSTR-3B
Content marked in red are newly inserted columns:
Details | IGST | CGST | SGST |
(A) ITC Available (whether in full or part) | |||
(1) Import of goods | |||
(2) Import of services | |||
(3) Inward supplies liable to reverse charge (other than 1 & 2 above) | |||
(4) Inward supplies from ISD | |||
(5) All other ITC | |||
(B) ITC Reversed | |||
(1) ITC Reversed (1) As per rules 38, 42, and 43 of CGST Rules and Section 17(5) | |||
(2) Others | |||
(C) Net ITC Available (A) – (B) | |||
(D) Other Details | |||
1) ITC reclaimed which was reversed under Table 4(B)(2) in the earlier tax period | |||
(2) Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions‖ |
Note:
- GSTIN has clarified that ITC to be reclaimed or may be reclaimed on any future date should be reported in Table 4B(2)-” ITC reversed-Others”. At the time of reclaim, ITC can be reclaimed through Table -4A(5), and additional disclosure shall be made in Table 4D(1) as well.
- However, ITC non-reclaimable shall be disclosed in Table 4B(1).
- Therefore, ITC once reversed through Table 4B(1) shall not be reclaimed.
2. Reporting of Reclaimable ITC
Case | Table-4A | Table-B | Table-D | ||||||||
Case: 1. ITC on goods where the invoice is received during the period but goods are received in the following tax period: | |||||||||||
a. Reporting in the month of receipt of goods | Claimed- Table-4A(5)-” All Other ITC” | Reversed-Table 4B(2)-” ITC Reversed-Other” | – | ||||||||
b. Reporting in the month of goods received | Reclaimed- Table-4A(5)-” All other ITC” | – | Additional Disclosure in Table-4D(1) | ||||||||
Case:2 ITC reversed on account of non-payment of GST within 180 days: | |||||||||||
a. Reporting in the month of receipt of goods | Claimed-Table-4A(5) | – | – | ||||||||
b. Reporting in a month when the period of 180 days expires | – | Reversal of such ITC shall be made in a month when 180 days expire in Table-4B(2) | – | ||||||||
Reporting in the month of payment | ITC Reclaimed- Table 4A(5) | Additional Disclosure- Table 4D(1) | |||||||||
Case: 3 Reversal of ITC on account of opting for Composition Scheme | |||||||||||
a. In the month when suppliers opt for a composition scheme | – | Table-4B(2) | Such ITC may be required to be reclaimed in the future. Therefore, the same is disclosed in 4B(2) | ||||||||
Case: 4 Reversal of ITC on cancellation of GST registration with respect to goods lying on date of cancellation | |||||||||||
a. In the month of cancelation of GSTIN | – | Table-4B(2)-” ITC Reversed-Other” | – |
3. Reporting of Non-Reclaimable ITC
Case | Table-4A | Table-B | Table-D | Remarks | |||||||
Case: 1. ITC Ineligible u/s 17(5) of CGST Act | |||||||||||
a. Reporting in the month of receipt of goods of service | Claimed- Table-4A(5)-” All Other ITC” | Reversed-Table 4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” | Such ITC shall not be disclosed in Table D as done earlier | ||||||||
Case:2 ITC ineligible because of the place of supply provisions or time-barred ITC u/s 16(4) of CGST Act | |||||||||||
a. Reporting in the month of receipt of goods or services | – | – | Table-4D(2)-” Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions” | Please note such ITC shall neither be disclosed in Table 4A nor 4B. | |||||||
Case:3 Reversal of ITC by banking companies u/s 17(4) of CGST Act | |||||||||||
a. Reporting in the month of receipt of goods or services | Table-4A(5) | Table-4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” | – | – | |||||||
Case:4 Reversal under Rule 42 and 43 of CGST Rules (Reversal due to use of Input/Input Services/Capital Goods partially for business purpose and partially for some other purpose) | |||||||||||
a. Reporting in the month of receipt of goods or services | Table-4A(5) | Table-4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” | – | – |
Notes:
- If any reversal made under Rule 42 or 43 or ITC shown as ineligible u/s 17(5) is required to be reclaimed in the following tax periods due to any reason then revised GSTR-3B does not provide any option for the same.
- A taxpayer may reclaim the ITC in Table 4A(5) but there is no row in Table 4D to disclose such reclaim.
4. Other Amendments
- For supplies made through e-commerce platforms, a separate Table 3.1.1(ii) has been inserted.
- Changes in GSTR-2B in line with revised GSTR-3B are still under process. Therefore, taxpayers may find pre-filled entries in GSTR-3B as not correct. Accordingly, taxpayers should reflect the changes required in the GSTR-3B return by way of editing the pre-filled entries so as to correctly self-assess the GSTR-3B return.
- Revised GSTR-2B would be available on GST Portal in due course of time.