GSTR-3B is a crucial document as it provides a summary of GST output and Inputs to the government. In Table-4 of GSTR-3B, bifurcation is provided of Input Tax Credit availed by the taxpayer.
However, the government noted that in various cases taxpayers were making incorrect disclosures in Table 4 leading to false information to the government. Therefore, the government suggested various changes in Table-4 of GSTR-3B vide Notification No. 14/2022-Central Tax dated 5th July 2022 and clarified various disclosure-related issues vide Circular No. 170/02/2022-GST dated 6th July 2022.
Accordingly, various amendments are made in GSTR-3B with effect from 01.09.2022 and the following are the reporting scenarios in Table 4 of GSTR-3B with effect from 01.09.2022.
1. Updated Format of Table-4 of GSTR-3B
Content marked in red are newly inserted columns:
| Details |
IGST |
CGST |
SGST |
| (A) ITC Available (whether in full or part) |
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| (1) Import of goods |
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| (2) Import of services |
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| (3) Inward supplies liable to reverse charge (other than 1 & 2 above) |
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| (4) Inward supplies from ISD |
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| (5) All other ITC |
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| (B) ITC Reversed |
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| (1) ITC Reversed (1) As per rules 38, 42, and 43 of CGST Rules and Section 17(5) |
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| (2) Others |
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| (C) Net ITC Available (A) – (B) |
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| (D) Other Details |
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| 1) ITC reclaimed which was reversed under Table 4(B)(2) in the earlier tax period |
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| (2) Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions‖ |
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Note:
- GSTIN has clarified that ITC to be reclaimed or may be reclaimed on any future date should be reported in Table 4B(2)-” ITC reversed-Others”. At the time of reclaim, ITC can be reclaimed through Table -4A(5), and additional disclosure shall be made in Table 4D(1) as well.
- However, ITC non-reclaimable shall be disclosed in Table 4B(1).
- Therefore, ITC once reversed through Table 4B(1) shall not be reclaimed.
2. Reporting of Reclaimable ITC
| Case |
Table-4A |
Table-B |
Table-D |
| Case: 1. ITC on goods where the invoice is received during the period but goods are received in the following tax period: |
| a. Reporting in the month of receipt of goods |
Claimed- Table-4A(5)-” All Other ITC” |
Reversed-Table 4B(2)-” ITC Reversed-Other” |
– |
| b. Reporting in the month of goods received |
Reclaimed- Table-4A(5)-” All other ITC” |
– |
Additional Disclosure in Table-4D(1) |
| Case:2 ITC reversed on account of non-payment of GST within 180 days: |
| a. Reporting in the month of receipt of goods |
Claimed-Table-4A(5) |
– |
– |
| b. Reporting in a month when the period of 180 days expires |
– |
Reversal of such ITC shall be made in a month when 180 days expire in Table-4B(2) |
– |
| Reporting in the month of payment |
ITC Reclaimed- Table 4A(5) |
|
Additional Disclosure- Table 4D(1) |
| Case: 3 Reversal of ITC on account of opting for Composition Scheme |
| a. In the month when suppliers opt for a composition scheme |
– |
Table-4B(2) |
Such ITC may be required to be reclaimed in the future. Therefore, the same is disclosed in 4B(2) |
| Case: 4 Reversal of ITC on cancellation of GST registration with respect to goods lying on date of cancellation |
| a. In the month of cancelation of GSTIN |
– |
Table-4B(2)-” ITC Reversed-Other” |
– |
3. Reporting of Non-Reclaimable ITC
| Case |
Table-4A |
Table-B |
Table-D |
Remarks |
| Case: 1. ITC Ineligible u/s 17(5) of CGST Act |
| a. Reporting in the month of receipt of goods or service |
Claimed- Table-4A(5)-” All Other ITC” |
Reversed-Table 4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” |
|
Such ITC shall not be disclosed in Table D as done earlier |
| Case:2 ITC ineligible because of the place of supply provisions or time-barred ITC u/s 16(4) of CGST Act |
| a. Reporting in the month of receipt of goods or services |
– |
– |
Table-4D(2)-” Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions” |
Please note such ITC shall neither be disclosed in Table 4A nor 4B. |
| Case:3 Reversal of ITC by banking companies u/s 17(4) of CGST Act |
| a. Reporting in the month of receipt of goods or services |
Table-4A(5) |
Table-4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” |
– |
– |
| Case:4 Reversal under Rule 42 and 43 of CGST Rules (Reversal due to use of Input/Input Services/Capital Goods partially for business purpose and partially for some other purpose) |
| a. Reporting in the month of receipt of goods or services |
Table-4A(5) |
Table-4B(1)-” ITC Reversed-As per rules 38, 42, and 43 of CGST Rules and Section 17(5)” |
– |
– |
Notes:
- If any reversal made under Rule 42 or 43 or ITC shown as ineligible u/s 17(5) is required to be reclaimed in the following tax periods due to any reason then revised GSTR-3B does not provide any option for the same.
- A taxpayer may reclaim the ITC in Table 4A(5) but there is no row in Table 4D to disclose such reclaim.
4. Other Amendments
- For supplies made through e-commerce platforms, a separate Table 3.1.1(ii) has been inserted.
- Changes in GSTR-2B in line with revised GSTR-3B are still under process. Therefore, taxpayers may find pre-filled entries in GSTR-3B as not correct. Accordingly, taxpayers should reflect the changes required in the GSTR-3B return by way of editing the pre-filled entries so as to correctly self-assess the GSTR-3B return.
- Revised GSTR-2B would be available on GST Portal in due course of time.
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