Input Tax Credit: Claiming ITC in GSTR-9 for Cross-Year Invoices

Input Tax Credit allows taxpayers to claim credit for the GST paid on purchases (inward supplies) against their GST liability on sales (outward supplies).

Cross-Year Invoices here means those invoices which are related to purchases made in FY 2023-24 but whose ITC is claimed in the following FY 2024-25.

Changes in Reporting Data in Table 8A From FY 2023-24

Up to FY 2022-23: In Table 8A of GSTR9, data derived from GSTR-2A, which dynamically updated based on supplier filings.

From FY 2023-24: Now in Table 8A derives data from GSTR-2B, a static return generated monthly after the due date of GSTR-1/IFF.

Reporting in Table 8C

What to Report?

ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the FY 2023-24 but availed in the FY 2024-25 up to specified period (November 30, 2024).

Problems in Filling Table 8C

  • Invoices reported by the supplier between April 23 – October 23 for FY 2022-23 were considered in Table 8A for FY 22-23.
  • But invoices for FY 2023-24 which appear in GSTR-2B for April 2024 to October 2024 are not reflecting in Table 8A, which creating a mismatch.

Solutions

Table 8C required to be put aggregate value of input tax credit availed on all inward supplies received during the FY but credit on which was availed in the next financial year up to specified period shall be declared here.

Example:

  • Invoice dated March 2024 is uploaded late and reflects in GSTR-2B for April 2024.
  • You claim ITC for this invoice in GSTR-3B for FY 2024-25 (before the specified period).
  • This ITC must be reported in Table 8C.

Impact on Table 8D

ITC auto-populated in Table 8A (based on GSTR-2B for FY 2023-24) – it will reflects in Table 6B and Table 8B also.

Impact

Since Table 8A only considers ITC reflected in GSTR-2B for FY 2023-24 (i.e., April 2023–March 2024), ITC claimed in the next (i.e., FY 2024-25) for FY 2023-24 invoices will not be part of 8A. This results in a discrepancy in Table 8D.

For this, taxpayers need to maintain working paper for future reference.

Issues while Reporting in GSTR-9: Explained

Question 1

Invoice having the date of FY 23-24 but the supplier has reported in the GSTR 1 after the due date of March’24. As a result, this amount is not auto populated in the Table 8A of GSTR 9 for FY 2023-24 because it is the part of next years GSTR 2B. How to report such transaction in the GSTR 9 of FY 23-24?

Answer – Taxpayer shall report such ITC in the Table 8C and in Table 13 as this is the ITC of FY 2023-24. This is in line with the instructions to the Table 8C and Table 13 of GSTR 9

Question 2

Invoice belongs to FY 23-24 and ITC has been claimed in FY 23-24. Due to payment not made to supplier within 180 days, ITC was reversed in 23-24 as per the second proviso to section 16(2) and this ITC is reclaimed in next Year FY 2024-25, after making the payment to supplier. How to report such transaction in the GSTR 9 of FY 23-24?

Answer – This reclaimed ITC shall be reported in the table 6H of GSTR 9 for FY 24-25 hence not in the Table 8C and Table 13 of GSTR 9 of FY 2023-24. This is in line with the Instruction to the Table 13 given in the Notified Form GSTR 9. Similar reporting is applicable for the ITC reclaimed as per Rule 37A.

Question 3

Invoice belongs to FY 2023-24 but goods not received in 23-24 therefore ITC is claimed in Table 4A5 of GSTR 3B and reversed in Table 4B2 as per the guidelines of Circular 170 and such ITC reclaimed in next FY 2024-25 till the specified time period. How to report such transaction in the GSTR 9 of FY 23-24?

Answer – Taxpayer shall report such reclaimed ITC in the Table 8C and Table 13 as this is the ITC of FY 2023-24.

Question 4

Invoice belongs to FY 22-23 which is appearing in the Table 8A of GSTR 9 of FY 23-24 , as the supplier would have reported the same in GSTR 1 after the due date of filing of GSTR-1 for the tax period of March 23. How to report such transaction in the GSTR 9 of FY 23-24?

Answer – This is the ITC of last year (2022-23) and was auto populated in table 8A of GSTR-9 of FY 22-23. Hence, aforesaid value need not to be reported in the table 8C and Table 13 of GSTR-9 for FY 23-24. This is in line with the instruction no 2A given for the notified form GSTR 9 which states that Table 4,5,6 and Table 7 should have the details of current FY only.

Question 5

Where to report the reclaim of ITC for an Invoice which belongs to FY 2023-24, and which is claimed, reversed and reclaimed in the same year?

Answer – As already clarified by the CBIC press release 3rd July 2019 in the para k, It may be noted that the label in Table 6H clearly states that information declared in Table 6H is exclusive of Table 6B. Therefore, information of such input tax credit is to be declared in one of the rows only.

Further, as the claim and reclaim is reported only in one row therefore the same should not be reported in the reversal under table 7 of GSTR 9 of FY 23-24.

Advisory on Difference in Value of Table 8A and 8C of GSTR-9 FY 23-24

Important Points to Note

  • Only invoices which reflected in GSTR-2B from April 2023 to March 2024 will appear in Table 8A.
  • Late-reported invoices (April–October 2024) won’t be included in 8A, leading to a gap.
  • Late-claimed ITC for FY 2023-24 invoices (claimed in FY 2024-25) must be added in Table 8C.
  • Regular reconciliation with GSTR-2B and books of accounts is essential to reduce discrepancies in Table 8D.

Conclusion

Businesses should monitor late-reported invoices and ensure accurate compliance with ITC provisions.

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