Analysis of New Disclosures in GSTR-3B
The 47th meeting of the GST council was held on 28th, and 29th June 2022. The GST council advised clarifying the furnishing of correct and relevant information on supplies of inter-state and the amount of blocked input tax credit as well as inverted thereof in form GSTR-3B.
The new modifications to the rules were furnished in Form-3B vide notification no 14/022-CT dated July 5th, 2022 with a clarification on the modified disclosures in circular no. 170/02/2022-GST dated 6th July 2022.
The taxpayers are now required to report their input tax credit (ITC) availment, inverted input tax credit (ITC), and ineligible/blocked input tax credit (ITC) carefully according to the new format of table 4 mentioned in the GSTR-3B in the GST portal.
A brief revised (Input Tax Credit ITC) table 4 of GSTR 3B:
Table No |
As per amended in GSTR3B |
As per old GSTR-3B |
4A. Input Tax Credit (ITC) available (either in part or full) |
||
4A(1) |
Import of Goods |
Import of goods |
4A(2) |
Import of services |
Import of services |
4A(3) |
Inward supplies liable for invert charge (other than 1 and 2 above) |
Inward supplies liable for invert charge (other than 1 and 2 above) |
4A(4) |
Inward supplies from ISD |
Inward supplies from ISD |
4A(5) |
All other input tax credit (ITC) |
All other input tax credit (ITC) |
4B. input tax credit (input tax credit (input tax credit (input tax credit (ITC) reserved |
||
4B(1) |
According to regulations 42 and 43 of CGST Rules |
According to the regulations 38, 42, and 43 of CGST regulations and sub-section (5) of section 17 |
4B(2) |
Others |
Others |
4D. Other details |
||
4D(1) |
Ineligible input tax credit (ITC): As per section 17(5) |
Additional information: input tax credit (ITC) reclaimed which was inverted as per table 4(B)(2) in earlier tax duration |
4D(2) |
Ineligible input tax credit (ITC): Others |
Additional information- Ineligible input tax credit (ITC) under section 16(4) and (ITC) limited due to PoS conditions |
Disclosures in GSTR-3B for the transactions of August 2022 and following:
1 |
input tax credit (ITC) on inward supplies (invoice) |
August-2022 |
August-22 |
Claim in GSTR-3B table A(5) |
Not applicable |
2 |
input tax credit (ITC) on inward supplies (invoice) |
August-2022 |
September-22 or following time |
No action and keep records of the same for the upcoming month |
Claim in GSTR-3B table 4A(5) |
3 |
input tax credit (ITC) on inward supplies (invoice) |
August-2022 |
Not available |
You can not avail input tax credit (ITC) for the time till same is available in the GSTR-2 and keep the records of the same for the upcoming month |
You can not avail input tax credit (ITC) for the time till same is available in the GSTR-2. The invoice-discerning details require to be kept a record of as “books only-eligible input tax credit (ITC)” in books |
4 |
input tax credit (ITC) on inward supplies (invoice) |
Sep-2022 |
August-22 |
1. Claim in GSTR-3B table 4A(5) 2. Reverse in GSTR-4B(2)-momentary inverted |
Claim in GSTR-3B table 4A(5) 2. Disclose in table 4D(1). |
5 |
inverted of input tax credit (ITC) n inward supplies (credit notes) |
Not available |
August-22 |
1. Claim in GSTR-3B table 4A(5) 2. Reverse in GSTR-4B(2)-momentary inverted |
After the annual reconciliation also if the input tax credit (ITC) is not pertaining to the taxpayers then the following shall be disclosure- Claim in GSTR-3B table 4A(5) 2. Reverse amount in table 4B(1)- permanent inverted. 3. Disclose in table 4D(1). If recorded in books in the later period, same as case 4 |
6 |
inverted of input tax credit (input tax credit (ITC) n inward supplies (credit notes) |
August-2022 |
August-22 |
CN would auto-populate in $B(2) however, it is not considered an inverted under rule 38,42,43 or section 17(5) and neither a momentary inverted. |
Not applicable |
7 |
inverted of input tax credit (ITC) n inward supplies (credit notes) |
August-22 |
September-22 or the following time |
Reverse in table 4A(5)-net off from all other input tax credit (ITC) |
Amount which would be auto-populated in the table 4B(2) is needed to be removed as the input tax credit (ITC) s already inverted in august-22 |
8 |
inverted of input tax credit (ITC) n inward supplies (credit notes) |
Sep-2022 or following period |
August-22 |
Amount which would be auto-populated in GSTR-3B – table 4A(5) or table 4B(2) is required to be removed. Suggested to keep a track of the same and looking out for the vendor clarifications of the identical |
CN would auto-populate in 4B(2). however, It is not inverted under rules 38,42,43 or section 17(5), and neither a momentary inverted. Consider as gross off in table 4A(5). |
9 |
inverted of input tax credit (ITC) on inward supplies (credit notes) |
August-22 |
Not available |
CN would auto-populate in 4B(2). however, It is not an inverted under rules 38,42,43 or section 17(5), and neither is a momentary inverted. Consider as gross off in the table 4A(5). . |
Not applicable |
10 |
inverted of input tax credit (ITC) n inward supplies (credit notes) |
Not available |
August-22 or following time |
Amount which would be auto-populated in GSTR-3B table 4B(2) is required to be removed. It is advised to maintain the record's track of the same and look out for the vendor clarifications of the identical |
Not applicable |
11 |
Invoice is dated August 2022 and stock not obtained in August 2022 but received in September 2022 for a later period. Accounted for in August-22 itself. |
August-22 |
August-22 |
1. Claim in GSTR-3B Table 4A(5) 2. Reverse in 4B(2) – momentary inverted |
1. Claim the amount in Table 4A(5) 2. Disclose in Table 4D(1). Regardless proclamations shall be in September-2022 or in afterward based on the month in which stock is obtained. |
12 |
inverted of input tax credit (ITC) due to payment not made within 180 days and reclaim in |
inverted accounting in August-22 |
Any month |
Reverse amount in Table 4B(2) – momentary inverted |
To reclaim input tax credit (ITC) in 3B upon payment to the vendor – 1. Claim the amount in Table 4A(5)2. Disclose in Table 4D(1) |
13 |
inverted of input tax credit (ITC) due payment not made within 180 days and reavail in an afterward period u/s 37 |
inverted accounting in August-22 |
Not available |
Reverse amount in Table 4B(2) – momentary inverted |
Where input tax credit (ITC) was otherwise eligible (covered in a buffer of 105% of (ITC) claim) – 1. Claim the amount in Table 4A(5)2. Disclose in Table 4D(1)Where input tax credit (ITC) was otherwise not eligible (may not be covered in the buffer of 105% claim), input tax credit (ITC) may not be claimed again. |
14 |
inverted of ineligible input tax (input tax credit (ITC) under rule 42/43 and mechanism to reavail incorrect inverted if there any |
August-22 |
August-22 |
1. Claim full amount in Table 4A(5) 2. Reverse in 4B(1) – permanent inverted (Reverse proportionate amount) |
This method is only for rectification of excess inverted input tax credit (ITC) and track of the same needs to be maintained 1. Claim proportionate amount in Table 4A(5) 2. Disclose in Table 4D(1) |
15 |
inverted of ineligible input tax (ITC) under rule 42/43 and mechanism to reavail incorrect inverted if there any |
September-22 |
August–22 |
1. Declare the full amount in Form GSTR-3B Table 4A(5) 2. Reverse in 4B(2) – momentary inverted (Reverse entire amount ) |
1. Claim full amount in Table 4A(5) 2. Reverse in 4B(1) – permanent inverted (Reverse proportionate amount) 3. Disclose in Table 4D(1) |
The procedures of the disclosure have been totally modified, Taxpayers are to be updated with all types of eligible and ineligible credits impacting their business. small-scale and medium-sized initiatives that may not presently have strong automated internal systems for accounting and reconciliation can go through some issues of problematic disclosures in the form of GSTR-3B, which may raise interventions for the department.
Also Read: Analysis 8 GST Notifications Issued 31st March 2023.
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