Amount of Ineligible/Blocked Input Tax Credit and Reversal thereof in Return FORM GSTR-3B
In this article, I am going to discuss only that part of the circular which is related to Table 4 of GSTR 3B.
Main object of the Circular 170/02/2022 dated 06-07-2022 (Specifically for GSTR 3B) is to guide for presentation of eligible, ineligible, reversal and reclaiming of reversed ITC in a proper and uniform manner nationally.
Format of GSTR 3B Table 4, is given below because various references will be helpful in understanding the circular and article.
GSTR 3B - Table 4. Eligible ITC
Details |
IGST |
CGST |
SGST |
Cess |
A. Eligible ITC |
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Import of Goods |
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Import of Service |
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Inward Supplier liable to Reverse Charge (Other than 1 & 2 above) |
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Inward Supplies from ISD |
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All other ITC |
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B. ITC Reversed |
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As per Rules 42 & 43 of CGST Rules |
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Others |
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C. Net ITC Available (A - B) |
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D. Ineligible ITC |
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As per Section 17(5) |
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Others |
Importantly, registered taxpayer is required to take Input Tax Credit (ITC) in Table 4(A) of GSTR 3B as per Part A of "ITC Available" Sheet of GSTR 2B. (As per me, RCM amount may be modified because all RCM data can not be there in GSTR 2B). All adjustments (for e.g. relating to ineligible ITC, invoice is received but goods are in transit, payment is not done within 180 days, etc.) should be done as mentioned in the circular and not by amending the amount directly in Table 4A of GSTR 3B.
Let us start. This will, in short and simple manner, guide us on which adjustment is to be done and where in table 4.
Table No of GSTR 3B |
Particulars of Table |
Adjustments to be made. |
Table4B: ITC Reversed |
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Table No. 4B(1) |
As per Rules 42 & 43 of CGST Rules |
Note: Any ITC which is not reclaimable will be reversed here. |
Table No. 4B(2) |
Others |
Not permanent in nature AND which can be reclaimed in future, subject to fulfillment of specific condition will be reversed here. Such as,
Note:
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Table 4D: Ineligible ITC |
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Table No. 4D(1) |
As per Section 17(5) |
All ITC which is reclaimed on fulfillment of specified condition (which was reversed in Table 4(B)(2)) shall be shown here. It is clarified that the reversal of ITC of ineligible credit under section 17(5) or any other provision of the CGST Act and Rules thereunder is required to be made under Table 4(B) and not under Table4(D) of Form GSTR 3B. (This para, in the entire circular, seems illogical to me. In Table 4(D)(1) of the Form GSTR 3B, it is mentioned that ITC ineligible under Section 17(5) is to be mentioned here and this circular denies to mention the same. Maybe in upcoming days, there will be some modification in GSTR 3B format) |
Table No. 4D(2) |
Others |
Note:
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Link for Circular: Click Here
Disclaimer: This is just for better and easy understanding, before coming to any conclusion of any confusion please read the notification with rules and act and consult to your tax consultant.