GSTN: CHANGES IN TABLE 4 OF GSTR-3B RELATED TO CLAIM OF ITC
It may be noted that the ineligible ITC, which was earlier not part of the calculation of eligible/available ITC, is now part of the calculation of eligible/available ITC in view of the auto-population of Table 4(A) of FORM GTSR-3B from various tables of FORM GTSR-2B
1. Population of ITC in GSTR 3B (Table 4A) – Total ITC (eligible as well as ineligible) is being auto-populated from FORM GSTR-2B, except for the ineligible ITC on account of the limitation of the time period as per Sec 16(4); or where the recipient of an intra-State supply is located in a different State / UT than that of POS
2. Reclaimable (non-permanent) Reversal to be reported in Table 4(B)(2) of GSTR 3B – ITC reversal which is not permanent in nature and which is to be reclaimed in the future subject to fulfillment of specific conditions i.e. (i) Rule 37 (non-payment of consideration to the supplier within 180 days), (ii) section 16(2)(b) (Receipt of goods or services at a later date); (iii) Section 16(2)(c) (Payment of tax by supplier subsequently)
3. Reclaim earlier reversed non-permanent ITC in Table 4(A)(5) of GSTR 3B – Such ITC may be reclaimed in Table 4(A)(5) on fulfillment of necessary conditions. Further, all such reclaimed ITC shall also be shown in Table 4(D)(1). Table 4 (B) (2) may also be used by a registered person for reversal of any ITC availed in Table 4(A) in previous tax periods because of some inadvertent mistake
4. Non-Reclaimable (Permanent) Reversal to be reported in Table 4(B)(1) of GSTR 3B – ITC reversal permanent in nature which is not to be reclaimed in future i.e. (i) Rule 38 (reversal of credit by a banking company or a financial institution), (ii) Rule 42 & 43 (reversal on input, input services, and Capital Goods on account of supply of exempted goods or services) (iii) Ineligible ITC under section 17(5).
5. Availment of Net ITC in Form GSTR 3B – The net ITC Available will be calculated in Table 4 (C) which is as per the formula (4A – [4B (1) + 4B (2)]) and same will be credited to the ECL of the registered person. To say total ITC populated (Table 4A) through Form GSTR 2B reduced by Permanent (Table 4(B)(1) and non-permanent (Table 4(B)(2) reversal.
6. Reporting of non-available ITC through Form GSTR 2B in Table 4D(2) of GSTR 3B – ITC not available, on account of the limitation of the time period as delineated in Sec 16(4) or POS being in different State, may be reported by the registered person in Table 4D (2). Such details are available in Table 4 of FORM GSTR-2B.
7. Correct disclosure of Reversal of ITC – Disclosure of ineligible credit u/s 17(5) or any other provisions of the CGST Act and rules thereunder is required to be made under Table 4(B) and NOT under Table 4(D) of FORM GSTR-3B.
CHANGES IN TABLE 4 OF GSTR-3B REPORTING OF ITC AVAILMENT, REVERSAL, AND INELIGIBLE OF ITC
1. The Government vide Notification No. 14/2022 — Central Tax dated 05th July, 2022 has notified few changes in Table 4 of Form GSTR-3B for enabling taxpayers to correctly report information regarding ITC availed, ITC reversal and ineligible ITC in Table 4 of GSTR-3B.
2. The Notified changes of Table 4 of GSTR-3B have been incorporated in GSTR-3B and are available on GST Portal since 01.09.2022.
The taxpayers are advised to report their ITC availment, reversal of ITC and ineligible ITC correctly as per the following format of Table 4 of GSTR-3B at GST Portal for the GSTR-3B to be filed for the period August 2022 onwards.
These changes in reporting in Table 4 are not applicable for the period prior to the August- 2022 period.
3. From the format of Table 4, following is noteworthy: I. All non-reclaimable reversal of ITC needs to be reported in table 4(B)(1) II.
All reclaimable ITC reversals may be reported in table 4(B)(2). It should be noted that ITC reversed under 4(B)(2) can be reclaimed in table 4(A)(5) at an appropriate time and the break-up detail of such reclaimed ITC should be provided in 4(D)(1) in the same return.
4. Corresponding changes in GSTR-2B and auto-population of GSTR-3B at present are under development and the taxpayer should reflect the changes required in GSTR-3B return by way of editing the pre-filled entries so as to correctly self-assess the GSTR-3B return. These changes would be available on GST Portal in due course of time.
5. Taxpayers may also refer to CBIC Circular No. 170/02/2022-GST dated 06th July, 2022 for detailed clarification on reporting of ITC availment, ITC reversal and Ineligible ITC in GSTR-3B
