Additional Reversal of Ineligible ITC in Table 7E of GSTR-9

[TAPAN RAI]

Dear Members,

Please guide whether we can do additional reversal of ineligible ITC thru Table 7E of Form GSTR-9. This ITC was earlier availed in monthly return Form 3B during 2017-18 but was not reversed till date.

Para 3 of the Trade Advisory Dt. 26.08.2019 says:-

Further, no input tax credit can be reversed or availed through the annual return. If taxpayers find themselves liable for reversing any input tax credit, they may do the same through FORM GST DRC-03 separately.

In view of this, what would be the correct way to reverse the ineligible ITC and give proper disclosure in either GSTR-9 or 9C.

Thanks & Regards

CA. Tapan Rai

[Atul Rathod]

It is preferable to show in table 7 of GSTR-9 & include such reversal of ITC in taxes payable (table 9)-there would be difference in taxes payable & taxes paid which would be discharged through DRC-03. In GSTR-9C figures would be attracted from 7J of annual return which will be after the above reversal.

[TAPAN RAI]

Sir,

Thank you for your reply.

I still have a doubt regarding the clarification given in the Trade Advisory that "no input tax credit can be reversed or availed through the annual return".

Would it be okay if we deposit the difference thru DRC-03 and give suitable remarks in the Certification part of GSTR-9C.

Kindly advise.

Thanks & Regards

CA. Tapan Rai

[KASTURI SETHI]

Notification no.74/18-CT dated 31.12.18 (serial no.9 above Table No.17) says that any differential amount of tax is to be paid in cash through DRC-03. How to be shown in GSTR 9 C has been rightly explained by Sh.Atul Rathod.

[TAPAN RAI]

Thank you Rathod Sir and Sethi Sir for your kind guidance.

AI Summary

Reversal of ineligible input tax credit must be paid via DRC-03 and disclosed in annual return and audit remarks.
Reversal of ineligible input tax credit cannot be effected through the annual return; taxpayers must disclose the reversal in the annual return's ITC tables, compute the resulting increase in taxes payable, pay the differential amount through the prescribed cash payment mechanism, and reflect the payment and explanation in the annual audit certification.