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Difference in ITC in FORM GSTR-3B &
GSTR-2A for F.Y. 2017-19

If there is a difference in GSTR-2A and GSTR-3B because of the reasons that supplier has

  1. failed to file GSTR-1 but filed GSTR-3B.
  2. filed GSTR-1 and GSTR-3B but failed to report a particular invoice in GSTR-1.
  3. wrongly reported the supply as B2C or B2B in his GSTR-1.
  4. filed GSTR-1 and GSTR-3B but declared the supply with the wrong GSTIN.

Then steps to be taken by the proper officer

  1. Check all the details of all the invoices on which the ITC has been availed by the recipient in GSTR-3B
    which are not reflected in GSTR-2A.
  2. Check all the condition mentioned in section 16 of CGST Act like whether the person
  • Is in possession of tax invoice and/or debit note.
  • Goods or services has been received.
  • Has made the complete payment inclusive of tax to the supplier.
  1. Check if any reversals as required by the law have been done.
  2. Check whether the tax with respect to that invoice on which the ITC is availed has been paid to the Govt. by the supplier.

If the ITC is claimed due to mentioning of the wrong GSTIN, then the proper officer of the actual recipient shall update the concerned jurisdiction about the same and disallow the ITC.
ITC pertaining to F.Y. 2017-18 can be claimed in GSTR-3B only till March 2019 only if the GSTR-1 of March 2019 is filed till the due date.

If the difference between ITC claimed in GSTR-3B and GSTR-2A is more than 5 lakhs.

The proper officer can ask the registered person to provide with a certificate from a Charted Accountant or Cost Accountant certifing that the invoices on which the ITC is claimed are for the goods or services
actually received by the recipient. The same certificate should have UDIN.

If the difference between ITC claimed in GSTR-3B and GSTR2A is upto 5 lakhs

The proper officer can ask the registered person to provide with a certificate from the concerned supplier certifing that the invoices on which the ITC is claimed are for the goods or services actually received
by the recipient and the tax has been paid by the supplier to the Govt. against the same invoice.

Aditi Mittal, Associate-Indirect Tax, SW India

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