TaxTMI 
TaxTMI 
Ground-2: Excess Availment of Input Tax Credit under IGST Act (GSTR-2A vs. GSTR-3B) -1
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....round-2: Excess Availment of Input Tax Credit under IGST Act (GSTR-2A vs. GSTR-3B) -1<br> Query (Issue) Started By: - Shambhavi Nayak Dated:- 21-3-2026 Last Reply Date:- 23-3-2026 Goods and Services Tax - GST<br>Got 2 Replies<br>GST<br>The Allegation: Upon verification of the books of accounts read with statutory returns Form GSTR-9 and Form GSTR-9C for the financial year 2021-22, it is observed t....
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....hat the Taxpayer has availed Input Tax Credit (ITC) under the IGST head amounting to Rs. 4,41,33,614.82, which is in excess of the auto-populated amount of Rs. 4,39,16,096.91 reflected in Form GSTR-2A (net of credit notes). It is pertinent to note that the records do not indicate any ITC brought forward from the preceding financial year, confirming that the subject claim pertains exclusively to tr....
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....ansactions within FY 2021-22. Consequently, the discrepancy of Rs. 2,17,517.91 constitutes an excess claim availed in direct contravention of the provisions of Section 16 of the GST Acts. Accordingly, the SCN proposed the recovery of Rs. 2,17,517.91 along with interest. Reply of the Taxpayer: The Taxpayer filed replies to the Show Cause Notice, including a submission dated 18-12-2025, contendin....
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....g the following: a. That they have followed Form GSTR-2B for availment of credit, which they claim is the correct basis. b. That the discrepancy in GSTR-2A arises because certain suppliers failed to report sales in GSTR-1 or reported them belatedly, and Credit Notes were issued by some dealers in 'April 2024' (appears to be a typographical error for 'April-2021') ....
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.... c. They relied on the judgment of the Hon'ble High Court of Orissa in M/s Raaas Corporate Service Pvt Ltd vs State of Odisha to argue that demand cannot be raised solely on mismatches. d. That they maintain a closing balance of Rs. 4,60,342/- in their Electronic Credit Ledger, and therefore, the demand is not sustainable. Reply By Raam Srinivasan Swaminathan Kalpathi: The....
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.... Reply: Dear Querist Kindly refer to the recent landmark judgment of the Tripura HC - re Sahil Enterprises - 2026 (1) TMI 385 - TRIPURA HIGH COURT delivered on Jan 6, 2026. Nevertheless, you have a strong case, if client had reported the reconciliation difference in GSTR-9C with appropriate explanations. Even otherwise, this is a fairly arguable case. Reply By KASTURI SETHI: The Reply....
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