16 February 2021
ITC as per 3B is Rs.100000 ITC as per 2A is 120000. difference is of rs 20000. Reason being Rs.30000 we have not taken in 3B and Rs.10000 not reflected in 2A. Auditors' asking for payment of Rs.10000..is it justified? As overall ITC in 2A is more than ITC in 3B even than payment required? If yes then as per Rule 36(4) too we are falling within 10% limit that was prevailing last year
16 February 2021
If that missing Rs 10000 is for before October 2019 then there is no need for reversal since Rule 36(4) got implemented from October. Secondly also check whether the supplier has updated till September 2020. If yes then there is no need to reverse.
16 February 2021
That 10% limit is just adhoc. In the truest sense it should have been invoice wise but to garner acceptability from tax payers the government said it to do monthwise. Just check whether the invoice has been shown till September 2020. If yes then no need to reverse. If no then you need to discuss it with your auditor and convince him for the 10% relaxation