Claim of ITC after filing of annual accounts

[ROHIT GOEL]

Dear Sir,

One of our clients filed their Financials for FY 2017-18 in August 2018. After filing of financials they realised that they had not claimed ITC on 3 invoices either in books (they had booked entire invoice value as Expense) neither in GSTR-3B.

Therefore, they claimed ITC on these invoices in Sep 2018 in GSTR-3B and also booked ITC in books (by reversing expense by way of Prior period item in Sep 2018).

Now:

1. If we disclose the said ITC in GSTR-9 of FY 2017-18 as ITC of FY 2017-18 claimed in Apr-Sep 2018, then it creates un-reconciled difference in GSTR-9C of FY 2017-18 as it has not been claimed in books and therefore creates tax demand in GSTR-9C.

2. However, instead if ITC is claimed in GSTR-9 of FY 2018-19, then it does not create any difference as ITC has been claimed in both Books and 3B in FY 2018-19. In this case, is such claim of ITC of FY 2017-18 in FY 2018-19 incorrect or bad in law?

Please express your kind views on the same.

[Atul Rathod]

Hi,

Disclose only in table 8 of GSTR-9. No where you need to disclose in GSTR-9C.

1. Say ₹ 100 has been claimed in BOA for 2017-18 whereas in returns for the period 2017-18 you have claimed 100 & 10 in Sep'18 return (in total for 2017-18-110)

2.₹ 100/- need to be disclosed in table 6 and ₹ 10 in table 8 of GSTR-9.

3. ₹ 100/- in table 12 of GSTR 9C & 10 would not appea anywhere.

4. Further table 13 of GSTR-9C picks the figure of annual return from table 7J which is total of table 6 & 7 of GSTR-9 but does not take effect of table 8.

5. Thereby it would not show any unreconciled item. Hope its clear.

AI Summary

Input tax credit reporting: disclose claim in GSTR-9 table eight in the annual return to avoid reconciliation mismatches. Disclose belatedly claimed input tax credit in the annual return under table 8 (adjustments/credits declared after year-end); amounts recorded in books for the prior year remain in the regular ITC table. This approach prevents unreconciled differences in the reconciliation statement because GSTR-9C's reconciliation figures derive from the main ITC and turnover tables and do not reflect the adjustment table.