GSTN : Discrepancies between Table 8A & Table 8C in GSTR-9

GSTN Advisory on discrepancies between Table 8A and Table 8C in Form GSTR-9

The GSTN has issued a detailed advisory to address taxpayers’ concerns about discrepancies between Table 8A (auto-populated from GSTR-2B) and Table 8C (manually entered for Input Tax Credit claimed in subsequent FY) in Form GSTR-9 for FY 2023-24. The GSTN Advisory No. 557, dated December 9, 2024, highlights an important issue regarding mismatches between Table 8A (Total Input Tax Credit on inward supplies) and Table 8C (Input Tax Credit availed in subsequent FY) of Form GSTR-9 for FY 2023-24.  The advisory clarifies various reporting scenarios to ensure compliance and accurate reconciliation of Input Tax Credit.  This problem arises due to changes in the data auto-population process, which affects the clarity and accuracy of Input Tax Credit reporting. The GSTN advisory stresses the significance of reconciling Table 8A and Table 8C accurately in Form GSTR-9.

Why Does the Table 8A and 8C Mismatch Occur?

GSTN Advisory on Differences Between Table 8A and 8C in GSTR-9 for Financial Year 2023-24.

Auto-population in Table 8A:

• Financial Year 2022-23: Based on GSTR-2A.
• FY 2023-24: Shifted to GSTR-2B, as per GST Notification No. 12/2024 (July 10, 2024) and GST Notification No. 20/2024 (October 8, 2024).
• Impact: GSTR-2B captures Input Tax Credit based on filing status and timing, potentially including prior Financial Year credits.

Manual Reporting in Table 8C:

Taxpayers must manually declare Input Tax Credit claimed for invoices from earlier years.

Steps to Handle Table 8A and 8C Mismatch

• Verify Auto-Populated Data in Table 8A: Cross-check the GSTR-2B summary against actual inward supplies for the reported financial year.
• Manually Reconcile Input Tax Credit for Table 8C: Identify and report carry-forward input tax credit or delayed claims manually. Ensure no duplicate reporting occurs.
• Cross-Check Previous FY ITC: Compare input tax credit claimed in GSTR-3B for earlier years to avoid overlap or omissions.
• Document Discrepancies: Maintain detailed records of mismatches and supporting documents for future audits.
• Raise Queries via GST Portal: Utilize GST helpdesk or grievance mechanisms to address unresolved issues.

Summary of the key scenarios and the correct reporting methods:

Scenario 1: Supplier Filed Invoice in GSTR-1 After March 2024

• Issue: An invoice dated Financial Year 2023-24 is reported in GSTR-1 after the March 2024 deadline. Hence, it appears in GSTR-2B of Financial Year 2024-25 and not in Table 8A of GSTR-9 for Financial Year 2023-24.
• Solution: Report the input tax credit in Table 8C (for delayed input tax credit claims). Also include it in Table 13, as per instructions to ensure complete reporting for FY 2023-24.

Scenario 2: ITC Reversed Due to Non-Payment Within 180 Days (Reclaimed in FY 2024-25)

• Issue: input tax credit claimed in FY 2023-24 is reversed as per Section 16(2), and subsequently reclaimed in Financial Year 2024-25 after supplier payment.
• Solution: Report reclaimed input tax credit in Table 6H of GSTR-9 for Financial Year 2024-25. Do not report it in Table 8C or Table 13 of Financial Year 2023-24, as per instructions in GSTR-9.

Scenario 3: ITC Reversed Due to Non-Receipt of Goods in FY 2023-24

• Issue: input tax credit initially claimed and reversed as per Circular 170 due to goods not being received. Input Tax Credit is subsequently reclaimed in Financial Year 2024-25.
• Solution: Report reclaimed input tax credit in Table 8C and Table 13 of GSTR-9 for Financial Year 2023-24, as it relates to that Financial Year.

Scenario 4: Invoice of Financial Year 2022-23 Appearing in Table 8A of Financial Year 2023-24

• Issue: The supplier reported an FY 2022-23 invoice in GSTR-1 after March 2023, causing it to appear in Table 8A of GSTR-9 for FY 2023-24.
• Solution: Do not report this value in Table 8C or Table 13 of FY 2023-24, as it belongs to the previous year (Financial Year 2022-23). Ensure compliance with instruction 2A of GSTR-9, which mandates that Tables 4, 5, 6, and 7 should reflect only the current financial year’s details.

Scenario 5: Claim, Reversal, and Reclaim of ITC in the Same Year

• Issue: Input Tax Credit is claimed, reversed, and reclaimed within Financial Year 2023-24.
• Solution: Report the reclaimed input tax credit in one row only of Table 6B or Table 6H, as per CBIC’s clarification (July 3, 2019). Do not report it again under Table 7 for reversals.

Consequences:

• Inflated ITC in Table 8A: Due to the inclusion of previous year’s (FY 2022-23) input tax credit in GSTR-2B for Financial Year 2023-24, leading to an overstatement.
• Lower Input Tax Credit in Table 8C: Manual entries in Table 8C often fail to reflect all carry-forward or delayed Input Tax Credit
• Taxpayer Confusion: Discrepancies between the two tables have led to multiple complaints and confusion over accurate input tax credit eligibility.

Relevant Case Laws and Legal Perspectives

• Madhya Pradesh High Court Ruling: highlighted the need for transparency in input tax credit reporting processes to prevent inadvertent penalties.
• Supreme Court in Calcutta Club Ltd.: Procedural errors should not deprive taxpayers of legitimate credits. The onus is on authorities to ensure fair processes.

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