September 12, 2022

Changes in GSTR-3B| With Effect from 01.09.2022

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.

DISCLAIMER: The views expressed are strictly of the author and VJM & Associates LLP. The contents of this article are solely for informational purpose. It does not constitute professional advice or recommendation of firm. Neither the author nor firm and its affiliates accepts any liabilities for any loss or damage of any kind arising out of any information in this article nor for any actions taken in reliance thereon.

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