Reversal of ITC as per GSTR 9

[Rajesh Kumar]

Sir/Madam

On going through the difference between GSTR-2A and GSTR-3B in GSTR-9, there is difference in negative which indicates that there was short ITC in 2A than claimed in 3B, however, today that difference is in positive I.e. ITC available in 2A is more than availed in 3B.

Now, was party to reverse the Excess ITC claimed as shown in GSTR-9 at the time of filing of R-9. If they did not do so, now they are required to reverse the same with interest thereon , however, the same is available today?

Department is insisting to reverse as per R-9 and stating that ITC was short as on Sept return filing date and available later is time barred as per Section 16(4). Is they right?

Second, ITC of 2018-19 availed between April to Sept of 2019-20 is required to minus from the calculation of ITC availed during 2019-20 as the same already calculated for 2018-19 as shown in R-9.

AI Summary

Input Tax Credit reconciliation: entitlement depends on statutory eligibility, not solely on automated purchase register timing.
Reconciliation of Input Tax Credit depends on satisfying statutory eligibility conditions rather than on automatic correspondence with the system purchase register; absence from the register on a reconciliation cut-off does not alone compel reversal, and taxpayers may substantiate excess claimed credit with corroborative documents or rely on subsequently reported supplier data, while tax authorities must show substantive disqualification rather than treat timing differences as an independent basis for reversal.