Update 26th August 2019: The finance ministry extended the last date for GSTR 9 Filing by three months to November 30 from 31st August 2019.
Table 8 of the annual return form GSTR 9 contains two sections.
The first section relates to the comparison of credit availed on forward charge by the taxpayer with the credit available as per inward supply uploaded by the suppliers in GSTR 1, duly reflected in GSTR 2A (Clause A to F of Sl. No.8).
The second section relates to the comparison of IGST paid on import of goods with IGST availed on import of goods (Clause G to J of Sl. No. 8). The differences in both the cases (Clause K of Sl. No. 8) is sought ‘to be lapsed’.
Clause A of Sl. No.8: ITC as per GSTR-2A (Table 3 & 5 thereof)
Clause A of Sl. No.8 is an auto-populated detail. The value of supplies along with relevant nature and amount of tax shall be auto-populated from Table 3 and 5 of Form GSTR-2A. Table 3 of GSTR 2A relates to ‘inward supplies received from a registered person other than the supplies attracting reverse charge’. Table 5 of GSTR 2A relates to ‘Debit/ Credit notes received during the current tax period’. Thus, what is auto-populated from GSTR 2A into this clause is only the data relating to credit availed on inward supplies, where GST is paid to suppliers and amendments made thereto in the form of debit/ credit notes.
Input tax credit availed on inward supplies received from a un-registered person under section 9(4) of CGST Act, 2017 cannot be cross-checked in GSTN. Input tax credit availed from registered persons, liable to reverse charge under section 9(3) is not sought to be reconciled in Sl. No.8
It is important to note that Table 8A of the annual returns is auto-populated from FORM GSTR-2A as on 1st May 2019.
Verification of GSTR 2A may bring forth the following discrepancies:
- The supplier may have uploaded the invoice with incorrect GSTIN. In such cases, the registered person may receive inward supplies not pertaining to it/ him. Since this value gets captured in GSTR 2A, it gets auto-populated in this clause.
- The registered person does not have any intention to take such credits in his GSTR 3B (the data from which gets reflected in Clauses B and C of Sl. No.8)
- Unknown purchases will lead to a difference in Clause D of Sl. No.8. This difference will have to be shown as ineligible credit in Clause F of Sl. No.8.
- Ineligible credit forming part of this clause is sought to be identified and reported in Clause F of Sl. No.8.
- A portion of GST paid on inward supplies may be ineligible u/s 17 and Rules made thereto. Ineligible credit would, however, form part of GSTR 2A when supplier uploads the same in GSTR 1.
- Purchases for which credit is ineligible
There could be cases where a single transaction could have two inward supplies in GSTR 2A. For example, the amount paid for the purchase of air ticket by the taxpayer would entail two inward supplies; one from the airline for the ticket and second from travel agent charging commission. Both the credits would be available even though the transaction is a single one (subject to conditions for availment of credit).
One of the conditions for availing the credit is that payment ought to be made to the supplier. However, payment would be made by the taxpayers only to travel agent and not the airline. The condition of making the payment would have been satisfied notwithstanding the fact that payment is not made directly to airline carrier in the instant case. Reference is drawn to Explanation (ii) to section 16(2)(b) of CGST Act, 2017, made by Central Goods and Service Tax (Amendment) Act, 2018.
- Value auto-populated in this clause to match with Column (3) of Sl. No.14 in GSTR 9C:
- It is pertinent to note that the aggregate value of inward supplies as per GSTR 2Aought to match with value as per Column (3) of Sl. No. 14 of GSTR 9C – ‘Amount of total ITC’.
- Column (3) of Point Sl. No. 14 of GSTR 9C gives expense wise break up of credit available on inward supplies, which is compared with credit availed as per Column 4.
- Inward supplies where GSTR 1 has not yet been filed till 30th April 2019.
- There could be cases where a registered person has paid consideration to suppliers and taken the credit based on invoice, but the supplier has not uploaded the invoices. In such cases, such invoices will be conspicuous by its absence, though the registered person has accounted for the said invoices and taken credit thereon.
- The registered person would not want to forego the credit merely because the supplier has not uploaded the invoices. The differential figure (due to the registered person taking credit while supplier has not uploaded invoice) will lead to a negative value in Clause D of Sl. No.8.
- in such cases, the taxpayer will have to reply to queries from the department seeking information as to why values are negative. The copy of the invoice (complying with all the conditions stated in Rule 46 of CGST Rules, 2017), the date of payment of consideration to the supplier are the primary documents/evidence to be safeguarded by the taxpayer in a case where the value in Clause D of Sl. No. 8 is negative due to failure on the part of the supplier to upload information.
- There could be instances where B2B supplies have wrongly been declared as B2C supplies, for failure to provide GSTIN by the taxpayer or due to genuine data entry error. If such supplies are in the nature of intra-State supplier or if such suppliers are in nature of inter-State supplies but the value of supply being less than Rs.2.50 lakhs, then the invoice level details may not have been entered in GSTR 1 by the supplier. Hence, such data will not travel to GSTR 2A and consequently to this clause in GSTR 9. This data entry error will get reflected in Clause D of Sl. No. 8. The registered person will thereafter have to take corrective action by intimating the supplier to correct his GSTR 1.
Sl. No. 8B: Input tax credit as per sum total of 6(B) and 6(H)
8B The input tax credit as declared in Table 6B and 6H shall be auto-populated here. The aggregate of input tax credit uploaded in Clause B and H of Sl. No.6 GSTR 9 gets auto-populated in this clause.
Clause B of Sl. No. 6 of GSTR-9 captures input tax credit pertaining to Inward Supplies (other than imports and inward supplies on which tax is to be paid on reverse charge but Includes services received from SEZ).
Input tax credit availed on import of goods and import of service is separately disclosed in Clause E and F of Sl. No.6. Inward supplies liable to reverse charge under section 9(3) and 9(4) is also separately disclosed in clause C and D of Sl. No.6 respectively. Hence, the aforesaid input tax credit is excluded in clause B of Sl. No.6.
Supplies of services received from SEZ are liable to tax on forward charge and GST on such supplies received from SEZ is eligible to be taken as a credit on a forward charge, subject to satisfaction of regular conditions under section 16 and 18 of CGST/ SGST Act. Hence, input tax credit paid on services received from SEZ is included in Clause B of Sl. No.6.
Clause H of Sl. No.6 relates to the aggregate value of input tax credit availed, reversed and reclaimed under the provisions of the GST Act, 2017. Hence credit reclaimed/ re-availed as per 2nd proviso to section 16(2) of CGST/ SGST Act, 2017 should be reflected here. Credit availed, reversed and reclaimed pursuant to Rule 42(2)(b) of CGST/ SGST Rules, 2017 also must be entered here.
This clause is also an auto-populated field which consolidates the values entered in Clause B and H of Sl. No.6 of GSTR-9. Clause B and H of Sl. No.6 captures the values entered in Table 4(A)(5) of GSTR-3B – ‘All other input tax credit’. This clause provides details of input tax availed on forward charge for the period July 17 to March 18.
Sl. No. 8C: ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during 2017-18 but availed between April 2018 and March 2019.
This clause reflects the figures of input tax credit pertaining to 2017-18 availed between April 2018 and March 2019 through GSTR 3B filed during the months of April 2018 to March 2019. In other words, GSTR 3B filed belatedly ‘for’ the months of 2017-18 ‘in’ the months of 2018-19 will continue to appear as credit availed ‘during 2017-18’ and not in this clause.
For example, GSTR 3B for the month of January 2018 filed during the month of August 18 will still be reflected as credits of January 2018 and reflected in Clause B of Sl. No.8 and not under this clause.
The values entered under this clause are required to be extracted from Table 4(A)(5) of GSTR 3B for April 2018 to March 2019. The values forming part of this clause must also form part of Sl. No 13 (Pt. V of GSTR 9) –‘ITC availed for the previous financial year’. Since Pt. V of GSTR 9 provides for ‘Particulars of the transaction for the previous financial year, declared in returns of April to September of the current financial year or up to the date of filing annual return, whichever is earlier’, this clause, as reflected in Sl. No.13 may be treated as an exceptional item by the revenue. The registered the person will be called upon to substantiate the data entered in Point No. 13, since it leads to a reduction in tax liability. Since data entered in Point No.13 ought to match with data entered in Point No. 8C, the registered person ought to have a working sheet with invoice wise line item wise data.
Sl. No.8D: Difference [8A-(8B+8C)]
Ideally, the value in this clause ought to be positive, since all inward supplies as reported in GSTR 2A may not be an eligible input tax credit. In the majority of circumstances, GSTR 2A will also contain blocked credit under section 17(5) and non-business credits under section 17(1), in addition to eligible credit. There could be credits used exclusively/ partially for exempt supplies, which will have to be dealt as per section 17(2), (3) of CGST Act, 2017 r/w Rule 42 and Rule 43 of CGST Rules, 2017. Hence this clause ought to generally declare a positive value.
However, in case this clause derives a negative value, it could point to the fact that ITC has been availed by the recipient, but the supplier has failed to upload the invoices in his GSTR 1, leading to the absence of corresponding credits and values in GSTR 2A of the registered person.
Negative values in this clause, in exceptional circumstances, could indicate errors or omissions/ commissions in the form of availing credit twice, availing excess credits due to typographic errors.
If the differential value in this clause is positive, then the value in this clause is normal. However, if the differential value in this clause is Zero or negative, it points to abnormal values. If the differential value in this clause is Zero, it tends to point to the fact that credit has been availed on inward supply and that there is no blocked credit, non-business credits. If the differential value in this clause is negative, it generally tends to point to the fact that suppliers have not uploaded their information in GSTR 1 leading to supplies not getting captured in GSTR 2A. Negative differential value in this clause may tend to point towards errors of commission/ duplication on the part of a registered person while availing credit.
Sl. No. 8E: Input tax credit available but not availed (out of 8D)
The aggregate value of the input tax credit which was available in FORM GSTR2A (table 3 & 5 only) but not availed in any of the FORM GSTR-3B returns shall be declared here. The credit shall be classified as credit which was available and not availed or the credit was not availed as the same was ineligible. The sum total of both rows should be equal to the difference in 8D.
Sl. No. 8F: ITC available but ineligible (out of 8D)
This clause has been inserted in the annual return to report that portion of input tax credit availed on forward charge, which is ineligible to be taken as credit due to provisions of section 17 of CGST Act, 2017 read with Rule 39 and 42 of CGST Rules, 2017.
Ineligible input tax credit is recorded in Table 4(D) of GSTR 3B. Ineligible input tax credit is divided into two parts:
- Input tax credit ineligible as per section 17(5) of CGST Act, 2017
- Other ineligible input tax credit
There could be cases where the registered person has uploaded only the eligible credit in Form GSTR 3B and completely omitted to enter ineligible credit in Table 4(D) of GSTR 3B for the period July 2017 to March 2018. In such cases, the information will have to be procured from books of accounts and entered here notwithstanding the fact that the said values are not entered in GSTR 3B since GSTR 2A will include all inward supplies including ineligible credit.
Sl. No. 8G: IGST paid on import of goods (including supplies from SEZ)
IGST paid on import of goods as well as IGST paid on inward supplies from SEZ Unit shall be captured in this clause.
Supplies of goods or services or both to or by an SEZ unit or SEZ developer is treated as an inter-State supply as per section 7(5) of IGST Act, 2017. Hence, supplies from the SEZ unit/ developer to DTA would be liable to IGST. Further as per section 30 of SEZ Act, 2005 any goods removed from SEZ to Developer ‘shall be chargeable to customs duty’, as leviable on such goods when imported.
Hence supplies by SEZ to DTA would be chargeable to IGST, as leviable when goods are imported into India. Hence this clause contains not only IGST paid on import of goods but also inward supplies from SEZ.
Sl. No. 8H: IGST credit availed on import of goods (as per 6E) above
IGST credit on import of goods including supplies from SEZ is reflected in 6E of GSTR 9. The data entered in 6E of GSTR 9 is auto-populated into 8H of GSTR 9. 6E is bifurcated in IGST paid on inputs and capital goods. The aggregate of IGST paid on inputs and capital goods are aggregated and auto-populated into 8H.
Notes to Consider:-
Table 8C considers ITC on inward supplies received during 17-18 but availed between April 18 and March 19. No such entry is there with respect to the import of goods on inward supplies received during 17-18 but availed between April 18 and March 19. Entry No. 8H auto-populates data from 6E. The said 6E considers credit availed on import of goods only for the period July 17 to March 18.
It has been clarified by CBIC via press release In respect of the imports during FY 2017-18 for which ITC was availed during Apr’18 to Mar’19, ITC shall be disclosed in Table 6(E) of Form GSTR-9.
Sl. No. 8I: Difference 8G-8H
Sl. No. 8I is not a data entry field. 8I merely shows the difference between IGST paid on import of goods, as reduced by IGST claimed on import of goods.
Clause J of Sl. No.8: ITC available but not availed on import of goods
Entry No. 8J reads as ‘ITC available but not availed on import of goods’, in effect it is related to an input tax credit available on import of goods but lapsed since amount entered in 8J is lapsed as per 8K.
Credit may not be available on import of the following goods:
- Goods imported which are not intended to be used in the course of business as per S.16(1)
- Goods imported which are used entirely for non-business purposes as per S.17(1)
- Goods imported which are used exclusively for exempt supplies as per S.17(2) and S.17(3)
- Goods imported which are blocked as credit u/s 17(5)
- Goods imported which are in the nature of telecommunication towers
Sl. No. 8K: Total ITC to be lapsed in the current financial year (E+F+J)
The total input tax credit which shall lapse for the current financial year shall be computed in this row.
This is merely an aggregate of total credit lapsed in 8E, 8F and 8J.
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