GSTR 2A VS TABLE 8 OF GSTR9

[sushanta saha]

Good Evening Experts, I have received a notice for GSTR-9- Mismatch in ITC & Table 8 for the FY 2017-2018.

In Notice Showed

Table 8 in GSTR 9 (Auto Generated)	8065224
ITC Claimed as per GSTR 3B	8709827
Difference	-644603

In GSTR 2A Total ITC Rs. 8709827/- and all supplier filled GSTR1.

I can’t understand why difference between GSTR-2A and table 8 in GSTR-9

[KASTURI SETHI]

Sh.Saha Ji,

Purchase invoices viz-a-viz GSTR 3B (comparision)

What is the status of purchase invoices ? What purchase invoices speak ? Check each invoice. Total amount of tax paid and credit taken on the strength of invoice should be examined with GSTR 3B.

There may be improper functioning of the software of Common Portal. Purchase invoices and physical receipt of goods are the actual basis for taking ITC as per Section 16 of CGST Act. You are also to ensure the eligibility aspect.

You are to justify the difference between the two on the basis of books of account.

[Padmanathan KV]

While GSTR-2A is dynamic, table 8 of GSTR-9 captures only ITC in GSTR-2A appearing as on 31st May 2019. you may refer to the advisory issued by GSTN in this regard.

In short, the difference ITC would be pertaining to invoices in GSTR-1 which were filed by suppliers after 31 May 2019.

[Shilpi Jain]

You can reply to the notice that the details are not sufficient to give reasons for the difference and also that during that period there was no provision in the law that the credit availed should be appearing in GSTR-2A.

Thereby there should be no liability to pay any tax on account of any difference.

[Padmanathan KV]

Practically, you can get a certificate under Circular No. 183/2022-GST and try to put an end to the matter.

(Please note that your case may not be directly covered under the circular as the invoices has already appeared in GSTR-2A and has not appeared in Table 8A of GSTR-9)

[Sudhir Kumar]

I would like to add one more point here in query that is if the GSTR-2A show excess availability of ITC but in column 8A of GSTR 9 show less ITC which is more authentic to rely on.

[KASTURI SETHI]

It is not a relevant question to know which is more authentic or more reliable. Whatever amount of ITC is shown in GSTR-2A must be supported by the purchase invoices. So regarding the reliability the foundation is purchase invoice, books of accounts, bank transactions etc. of both supplier and the buyer.

However, GTR 2A is one of the bases of all other returns including GSTR 9.

[KASTURI SETHI]

You are also to take care of admissibility /inadmissibility of ITC. If ITC is hit by Section 17 (5) of CGST Act you are to reverse ITC in GSTR-3B return. ITC shown in GSTR-2A cannot be taken for granted.

Emphasis should be laid on genuineness of purchase invoices and genuineness of bank transactions .

[GUNASEKARAN K]

There are so many reason for mismatch of ITC between GSTR 2A and Table 8 in GSTR 9

Related outward supply invoices are submitted by the supplier’s GSTR-1 may not file the return. The GSTR-2A will display the status “Not yet filed” in case of such invoices.

Delayed filing of GSTR-1 return by the supplier after the due date will not show in Table 8A in GSTR 9.

Supplier may amend the GSTIN of the Invoice in subsequent month after filing of GSTR 1 then the ITC will reflect in B2BA sheet or Invoices filed wrongly as "Liable to RCM" will not show in Table 8A of the recipient.

Supplier converted from Composite Scheme to Regular Taxpayer Scheme, the date of invoice prior to change regular taxpayer scheme then the ITC relating to those purchase invoices will show in Table 8A of GSTR 9.

Apart from these reason, there may be so may technical issues may be reason to mismatch of ITC between GSTR 2A & Table 8 of GSTR 9.