Precious 20 days: Must take all efforts to ensure that all the eligible Input Tax Credit (ITC) of the invoices pertaining to F.Y.2017-18 are taken.

[Ganeshan Kalyani]

The time limit to claim input tax credit of the invoices pertaining to financial year 2017-18 is 20th April, 2019. As per the provision the time limit was 20th October, 2018. But since the financial year 2017-18 is the first year of implementation of Goods and Service Tax, the Central Board of Indirect Tax has extended the time lime up to 20th April, 2019. The unclaimed input tax credit of the said financial year can be claimed thru GSTR-3B of March, 2019 to be filed on or before 20th April, 2019. Thus, these are the crucial 20 days for the tax person of any organization to ensure that no eligible input tax credit are pending to be claimed. If there remains any input tax credit pending to be claimed then it would lapse. In such case the input tax credit cannot be claimed. Refer Order No.02/2018-Central Tax dated 31st December, 2018.

Reiterating the importance of the matching the input tax credit already claimed on a  monthly basis in Form GSTR-3B with the input tax credit auto-populating in the GSTR-2A report. The said report is available in a downloadable format after login into www.gst.gov.in. The name of the supplier and invoice number is available  in the report. A tax person must have prepared input tax credit ledger having the name of the supplier and the invoice number for the purpose of filing GSTR-3B. If one combines the name of the supplier and invoice number in one column in both the respective excel sheet i.e. in 2A report and 3B working sheet. Then a common field would be available for applying vlookup and match the figures easily.

The invoice matching task is tedious and challenging especially for a big organization having existence in almost all the States. One of the reason being is that the matching activity was not carried out on a monthly basis by most of the registered person. Had the activity was carried out on a regular basis the registered person would not have to stretch lot to match invoices for the period of nine months in the first year of GST. The registered person must realize that these are the last 20 days available in the hands of the registered person to identify the unclaimed input tax credit on the invoices pertaining to F.Y. 2017-18 and claim it in the GSTR-3B for the month of March, 2019.

Presently, the claim of input tax credit thru GSTR-3B is on self assessment basis. That is the total eligible input tax credit is worked out and claimed thru GSTR-3B. The invoice wise details are not uploaded in the GSTN. Though the provision does not restricts the registered person to claim input tax credit of the invoices only if they are auto populating in the GSTR 2A- But it would be a better method to match the invoices and for mismatch records do write an email or call and inform to the supplier to upload the invoices which are appearing in books of buyer but missed out by the supplier to upload it in GST return. The correspondence would be very much helpful if the authority objects the credit during the conduct of audit or assessment.

It is worth noting that in case an input, capital goods or services are used for both taxable and non taxable goods then the input tax credit would be allowed in the proportion of taxable goods. If any credit is wrongly availed and utilized then that credit should be immediately reversed along with the payment of applicable interest.

Discussions to this article

[Nisha Prabhu]

Whether reversal of input tax credit not reflecting in GSTR-2A be considered in Mar-19 GSTR-3B returns?

[Ganeshan Kalyani]

Can you please elaborate your query ?