GST Advisory on the difference in the value of Table 8A and 8C of GSTR 9 FY 23-24!

On October 8, 2024, the CBIC issued Notification No. 20/2024-Central Tax, announcing that starting from FY 2023-24, the amounts in GSTR-9 Table 8A would be auto-populated from GSTR-2B instead of GSTR-2A. However, this change led to confusion among taxpayers regarding the reconciliation and disclosure of ITC in specific scenarios, such as cases where ITC for March 2024 was not reflected in GSTR-2B due to delayed filing of GSTR-1 and some other cases. To address these concerns, GSTN released an advisory on December 9, 2024.

Let's understand the details!

Advisory dated 09^th December 2024

Advisory on the difference in the value of Table 8A and 8C of Annual Returns FY 23-24

Dec 9th, 2024

1. As per Notification No 12/2024 Central Tax dated 10th July 2024 read with Notification No.20/2024-Central Tax Dated 8th October 2024, for FY 2023-24 onwards, the total credit available for inwards supplies shall be auto-populated in table 8A of Form GSTR 9 from GSTR-2B of the FY 23-24. Further, in table 8C of Form GSTR-9 total value of ITC on inwards supplies received during the FY but availed in the next FY up to the specified period, needs to be filled manually.

2. Various tickets are received, wherein concerns have been raised regarding possible mismatch between the values of table 8A and 8C of Form GSTR-9 for FY 23-24. It is pertinent to mention that for FY 22-23 in table 8A of Form GSTR-9, values were getting auto-populated from GSTR-2A however for FY 23-24 same are being auto-populated from GSTR-2B. Therefore, to some extent, in Form GSTR-9 of FY 23-24, values in Table 8A will be inflated in respect of FY 22-23 at the same time values will be lower than expected in respect of FY 23-24, hence there will be a mismatch between the two tables i.e. 8A and 8C. Few scenarios in this regard are advised here under:-

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Key Highlights of the Advisory

• Table 8A of GSTR 9 states the amounts of ITC as per GSTR 2B. 8B states the amounts of ITC as per books. 8C states the amounts of ITC of the current financial year which is claimed in next financial year.

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• Till FY 2022-23, Table 8A of GSTR 9 was populated from GSTR 2A. From FY 2023-24 onwards, it is populated from GSTR 2B. Various concerns were raised by the taxpayers regarding a possible mismatch between the values of Table 8A and 8C of Form GSTR-9 for FY 23-24, being the first year of such change.
• To clarify this matter, the GSTN issued an advisory that has addressed 5 issues as follows:

1. The supplier filed GSTR 1 of March 2024 after the due date. Therefore, such ITC is not captured in Table 8A of GSTR 2B: It shall be reported in Table 8C and in Table 13.
2. The supplier filed GSTR 1 of March 2023 after the due date. Therefore, such ITC is captured in Table 8A of GSTR 2B for FY 2023-24: It is not to be reported in table 8C and Table 13 of GSTR-9 for FY 2023-24.
3. In FY 2023-24, ITC was reversed due to non-payment to the supplier within 180 days. It is re-claimed in FY 2024-25: This shall be reported Table 6H of GSTR 9 for FY 2024-25. No reporting is required in Table 8C and Table 13 of GSTR 9 of FY 2023-24.
4. Invoice belongs to FY 2023-24 but goods not received in 23-24 therefore ITC is claimed in Table 4A5 of GSTR 3B and reversed in Table 4B2. Such ITC is reclaimed in the next FY 2024-25: Taxpayer shall report such reclaimed ITC in Table 8C and Table 13 as this is the ITC of FY 2023-24.
5. Reporting the reclaim of ITC for an Invoice that belongs to FY 2023-24, and which is claimed, reversed, and reclaimed in the same year: As already clarified by the CBIC press release on 3rd July 2019 in the para k, It may be noted that the label in Table 6H clearly states that information declared in Table 6H is exclusive of Table 6B. Therefore, information of such input tax credit is to be declared in one of the rows only. Further, as the claim and reclaim is reported only in one row therefore the same should not be reported in the reversal under table 7 of GSTR 9 of FY 23-24.

Conclusion

‍The GST Advisory issued on December 9, 2024, provides much-needed clarity on the reporting of Input Tax Credit (ITC) discrepancies in GSTR-9 for FY 2023-24. With the transition from GSTR-2A to GSTR-2B for Table 8A auto-population, taxpayers faced challenges in reconciling ITC data, especially in cases involving late filings, reversals, and reclaims. The advisory addresses these concerns with detailed reporting guidelines for various scenarios, ensuring taxpayers can comply with GST requirements effectively. By addressing potential mismatches between Table 8A and 8C and providing clear instructions for ITC disclosure, the GSTN has facilitated a smoother compliance process and reduced ambiguity for businesses.