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Advisory on Differences in Value of Table 8A and 8C in Annual Returns for FY 2023-24

Differences in Value of Table 8A and 8C in Annual Returns-GST Course in Coimbatore

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The Goods and Services Tax (GST) Annual Return, particularly Table 8, often becomes a focus during reconciliation. For FY 2023-24, taxpayers might notice differences between Table 8A (ITC auto-populated from GSTR-2B) and Table 8C (ITC claimed in GSTR-3B). Understanding these discrepancies is crucial to ensure compliance, avoid penalties, and optimize Input Tax Credit (ITC) claims.

Overview of Table 8A and 8C

Table 8A: Reflects ITC auto-populated from GSTR-2B, which includes details reported by suppliers in their GSTR-1 or GSTR-5. This table auto-populates the total Input Tax Credit (ITC) available for inward supplies during the financial year, sourced from GSTR-2B. GSTR-2B provides a static view of ITC eligibility, which may result in values in Table 8A being higher compared to the previous financial year (FY 2022-23).

Table 8C: Shows the ITC claimed by the taxpayer in GSTR-3B for the corresponding financial year. This table requires manual reporting of ITC on inward supplies received during the FY but availed in the subsequent financial year up to the specified period. The values in Table 8C may appear lower than expected for FY 2023-24 due to the manual nature of reporting and the timing of ITC availment.

Common Scenarios Leading to Discrepancies

Late Reporting by Supplier: If an invoice dated in FY 2023-24 is reported by the supplier in GSTR-1 after the due date (March 2024), it will not auto-populate in Table 8A for FY 2023-24. In such cases, the ITC should be reported in Table 8C and Table 13 of GSTR-9 for FY 2023-24.

ITC Reversed and Reclaimed: If ITC claimed in FY 2023-24 is reversed due to non-payment to the supplier within 180 days and later reclaimed in FY 2024-25, the reclaimed ITC should be reported in Table 6H of GSTR-9 for FY 2024-25, not in Table 8C or Table 13 of FY 2023-24.

Goods Not Received in FY 2023-24: If goods related to an invoice dated in FY 2023-24 are not received within the same financial year, leading to ITC reversal, and the ITC is reclaimed in FY 2024-25, it should be reported in Table 8C and Table 13 of GSTR-9 for FY 2023-24.

By understanding these differences, businesses can ensure accurate reporting in their annual GST returns and stay compliant with tax laws for FY 2023-24. Regular checks, reconciliations, and timely filing will help in avoiding penalties and reducing the risk of errors in returns.

Compliance and Reporting Tips

September 2021 GST returns - Time to do self-assessment of books of accounts from GST Stand point of view for Financial Year 2020- 2021

Business had a challenging financial year. There was disruption to normal business due to Covid-19 pandemic. Government extended due dates for various returns, waiver of interest for late of payment and for delayed filing of returns for Small, MSMEs as well as large taxpayers. Government was extending the concessions based on rapidly changing situation. In view of the above, there is need to reconcile books with returns. Taxpayers have an opportunity to correct those errors committed unintentionally in their GST returns during financial year 2020-21.

Taxpayers needs to examine, resolve and reconcile the books with returns before filing of their monthly return for September 2021. A few areas are mentioned below, which they can review and act upon:

Sales

GSTR1- Reconciliation of Sales register with GSTR1. In case of any difference, make appropriate corrections.
GSTR3B - The same exercise needs to be repeated done with GSTR-3B.
Financial books – It needs to be tallied sales uploaded in the GST portal.
Export invoices – Ensure it is properly correlated with Customs to get refund seamlessly.
Examine and confirm that correct reporting of NIL rated, exempted and non-taxable supplies in the GSTR-1.
Advances from Customers – Examine the following:
Whether if any advances received during the year?
If yes, check if it is settled, then necessary adjustments should be carried out in books and GST portal.
Sales/Debit notes/Credit notes of previous year (FY: 2019-20) reported in the during period from April 2020 to March 2021 needs to be deducted.
In the same manner, Sales/Debit notes/Credit notes for the FY: 2020-21 reported after March 2021, needs to be added to arrive at the correct turnover.
Credit notes pertaining to financial year 2020-21, which is pending to be reported in the GST portal should be done in September 2021. If not, you can only use the commercial credit note without any adjustment of GST liability.
In case of any invoices or debit note or credit note is missed out including any corrections to invoice number, date, taxable value and total value can be done while filing the GSTR1.

Input Tax Credit (ITC)

Examine, analysis and reconciliation of purchase register with GSTR-2A/2B availed in GST returns of FY 2020-21.
Avail any unclaimed ITC of FY 2020-21 in September 2021 GSTR-3B.
If any ITC is not received, co-ordinate with supplier and ensure your ITC is credited in GSTR2A/2B. In the same way, if any supplier has mis-spelt your GSTIN, request them to necessary correction.
Check and request supplier to rectify the transactions if they had wrongly linked your invoice as B2C instead of B2B.
Prepare list of the eligible and ineligible ITCs separately. This is required for reporting in annual return. Reconcile them with the physical copy of the invoices/debit notes. If any missing, please collect from vendors.
Analyze ITC availed and reversed in the GST returns during the last year. If any ineligible ITC wrongly recorded in the eligible credit and vice versa, please do the necessary corrections.
Reverse Charge Mechanism (RCM): Identify if supplies subject to RCM under GST had been correctly disclosed in GSTR-3B return
ITC needs to be reversed, if the payment to Vendor’s invoice/debit note is not made within 180 days as per Rules 37 of CGST Rules, 2017.
ITC reflected in GSTR-2A without corresponding invoice, please collect the same with vendor. The opposite – invoice is available with you but ITC not reflected in GSTR-2A, request vendor to file invoices details in their September 2021 GSTR-1, if not, please reverse them.
If Rule 42 and 43 is applicable to your business, then ITC should be reversed in the following manner:
- Actual reversal as per formula.
- If the actual ITC calculation is less than actual reversal, reverse the balance ITC in September 2021 GSTR-3B or pay the same through Form GST DRC-03 along with interest at the rate of 18%. The interest will be calculated from April 01, 2021 (in respect of FY 2020-21) till the date of reversal or actual payment, as the case maybe.
- If the excess ITC reversed, claim the same in September 2021.

Payment

Check on whether correct GST rates is used along with proper HSN/SAC codes to ensure accuracy of tax liability arrived upon.
Liability due and corresponding payments made during the year needs to be mapped correctly.

Registers

Balance in credit registers is reconciled with financial books.

If you are able to validate the points, then you can comfortably able to file your annual returns for the financial year 2020-21.

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