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Advisory: Filing of Annexure-B (ITC Refund):

Nikunj Kishorbhai Tosar
ITC refund reconciliation issues arise when Annexure-B line-item details must match GSTR-3B for non-monthly refund periods. Line-item-wise reporting in Annexure-B for ITC refund requires the ITC availed in GSTR-3B to be furnished with additional detail, even where the net refund claim excludes capital goods ITC, permanent reversal under 4(B)(1), and temporary reversal under 4(B)(2). Monthly refund filings are better suited to matching Annexure-B with GSTR-3B details, while quarterly or half-yearly refund periods may create reconciliation challenges, especially for taxpayers following the reversal-and-reclaim methodology. (AI Summary)

Referring to the latest issued advisory, it seems that line items wise details to be furnished in Annexure-B of ITC availed in GSTR-3B.

If ITC availed in GSTR-3B = ITC to be reported in Annexure-B then,
Additional information is required to be furnished, even though the Net ITC amount claimed for refund purpose is excluding the below details:

  • Capital Goods ITC
  • Permanent Reversal 4(B)(1)
  • Temporary Reverse 4(B)(2).

Although, Theses information can be furnished accurately if the Refund application is filed on Monthly basis to match with ITC availed in GSTR-3B

However, when refund period is quarterly or half yearly (other than monthly), then to provide line-item wise details as furnished in respective GSTR-3B is difficult pursuant to effect of circular 170 and reversal and reclaim cycle.

Accordingly, taxpayers following reversal and reclaim methodology may face reconciliation challenges while preparing Annexure-B for non-monthly refund periods.

P.S.: Taxpayers who are not following the reversal-reclaim mechanism / Circular 170 methodology may comparatively remain in a safer position from reconciliation issues under the present system.

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