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.
TaxTMI
TaxTMI