1. ANALYSIS OF INPUT TAX CREDIT
GSTR -9
ANALYSIS OF INPUT TAX CREDIT
(WITH CASE STUDIES)
Presented at: ICAI, Guwahati
By: CA. Raginee Goyal, FCA, DISA (ICAI)

2. ANNUAL RETURN – FLOW OF DATA
NATURE
TAX DECLARED IN ?
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
BOOKS = TABLE (4 + 5) + TABLE (10 – 11)
INWARD SUPPLIES
BOOKS = FY FY 18-19
TAXES PAID
Actual = FY FY FY 19-20

3. ANNUAL RETURN – FLOW OF DATA
NATURE
TAX DECLARED IN ?
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
Treatment
BOOKS = TABLE (4 & 5) + TABLE (10 & 11)
INWARD SUPPLIES
BOOKS = FY FY 18-19
TAXES PAID
Actual = FY FY FY 19-20 or ?

4. ANNUAL RETURN – FLOW OF DATA
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
BOOKS = TABLE (4 + 5) + TABLE (10 – 11)
INWARD SUPPLIES
BOOKS = FY FY Missed Till Now
TAXES PAID
Actual = FY FY FY 19-20

5. ANNUAL RETURN – FLOW OF DATA
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
BOOKS = TABLE (4 & 5) + TABLE (10 & 11)
INWARD SUPPLIES
BOOKS = FY FY Missed Till Now
Treatment
BOOKS = TABLE (6 & 7) + TABLE (12 & 13)
TAXES PAID
Actual = FY FY FY 19-20 or ? ?

6. ANNUAL RETURN – FLOW OF DATA
NATURE
TAX DECLARED IN ?
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
BOOKS = TABLE (4 + 5) + TABLE (10 – 11)
INWARD SUPPLIES
BOOKS = FY FY 18-19
TAXES PAID
Actual Tax Paid (3B + DRC-03)
= FY FY FY 19-20

7. ANNUAL RETURN – FLOW OF DATA
NATURE
TAX DECLARED IN ?
OUTWARD SUPPLIES
BOOKS = FY FY FY 19-20
BOOKS = TABLE (4 + 5) + TABLE (10 – 11)
INWARD SUPPLIES
BOOKS = FY FY 18-19
TAXES PAID
Actual Tax Paid (3B + DRC-03)
= FY FY FY 19-20
Treatment
= Table 9 (Auto & Un-Editable) + Table 14 (Manual) ?

8. TABLE 4 of GSTR-3B
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

9. Part-III (Details of ITC claimed, reversal, available & lapsed)6
Description
Type
CGST
SGST
IGST
CESS
Form
Table
Period 6A
Total ITC Claimed in GSTR-3B 6B
Inward Supplies of Goods and Services as well as Services from SEZ (all claims in 3B and also reflected in 2A) [other than RCM]
Inputs
GSTR-3B
4(A)(5)
As per Books from July-2017 to March-2018
Capital Goods
Input Services 6C
RCM paid & ITC Claimed on B2C Inwards [for RCM of 9(4) & unregistered 9(3)]]
4(A)(3) 6D
RCM paid & ITC Claimed on B2B inwards [for RCM of registered 9(3)] 6E
Import of Goods incl. SEZ
4(A)(1) 6F
Import of Services excluding SEZ
4(A)(2) 6G
ITC received from ISD
4(A)(4) 6H
Total ITC re-Claimed (Other than 6B above)

10. Part-III (Details of ITC claimed, reversal, available & lapsed)6
Description
Type
CGST
SGST
IGST
CESS
Form
Table 6I
Sub-total (6B to 6H above) because 6A is Auto populated Figure 6J
Difference (I - A above) ( Ideally it should be Zero means 3B figures tally with the figures now we have filled up) or (If there is difference then it means certain input claims through Amendments in 3B in next year for which reconciliation will be done in another part of this form later) 6K
TRAN-1 Claimed (Auto)
 Electronic Credit Ledger 6L
TRAN-2 Claimed (Auto) 6M
Any Other ITC availed but not specified above
ITC-01/02 6N
Sub-total (K to M above) (Only Transitional Claim + Other ITC) 6O
Total of ITC availed (I+N) (Books Claim + Transitional Claim)

11. Details of ITC Reversed7
Details of ITC Reversed
CGST
SGST
IGST
CESS
Form
Table 7A
As per Rule 37 (ITC reversal for non payment of consideration within 180 days)
GSTR-3B 4B 7B
As per Rule 39 (ITC distribution by ISD and its reversal) 7C
As per Rule 42 (ITC attributable to exempt supply) 7D
As per Rule 43 (ITC reversal on capital goods used for manufacturing exempt supplies) 7E
As per section 17(5) blocked credit like vehicle, Food & Beverage, Outdoor Catering, Beauty Treatment, Health services, Club membership, rent a cab, health insurance, free sample gift, lost destroyed, etc.) 7F
Reversal of TRAN-I credit 7G
Reversal of TRAN-II credit 7H
Other reversals (pl. specify)
ITC-03 7I
Total ITC Reversed (7A to 7H above) 7J
Net ITC Available for Utilization (6O - 7I)

12. OTHER ITC RELATED INFORMATION8
OTHER ITC RELATED INFORMATIONS
CGST
SGST
IGST
CESS
Form
Table
Period 8A
ITC AS PER GSTR-2A
<Auto>
July-17 to March-18 8B
ITC AS PER GSTR-3B 8C
ITC ON INWARD SUPPLIES BUT CLAIMED IN GSTR-3B FROM April to Sep-2018? March 2019?
Table 13 & 12
Old ITC but Taken now 8D
Difference [A-(B+C)] (Preferable should be zero or if Positive means Unclaimed due to our mistake or not related to us or ineligible or related to Exempt Supply) (if negative then supplier did not file return or otherwise) 8E
ITC Available but not availed (Out of D above) (Exists in 2A but not availed in 3B) 8F
ITC available but ineligible or related to Exempt (7A/7B) 8G
IGST paid on Import of Goods or Services (Icegate) data of BOE 8H
IGST Credit availed on Import of Goods(As 6E and 6F above) (As per Books)
 As per 3(B) Auto 8I
Difference (8G-8H) (Actual Payment Vs. Books of Accounts) IMPACT? 8J
ITC Available but not availed on import of Goods (Equal to 8I) 8K
Total ITC to be lapsed in current financial year (E+F+J) (Due to non proper working + not related to us + Ineligible credit due to exempt supply + Non proper accounting on Import Bills)

13. FORM GSTR-9 (Table 6 & 7)
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

14. FORM GSTR-9 (Table 6 & 7)
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

15. FORM GSTR-9 (Table 6 & 7)
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

16. FORM GSTR-9 - PART V (MOST IMPORTANT)
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

17. FORM GSTR Table 8
The appointed date for effective implementation of the provisions of the GST laws is , i.e., from the second quarter of the financial year Therefore, the very applicability of the threshold limits for audit purposes, whether wholly (Rs.2 Crore) or in proportion, has not been explicitly provided for – Clarification from the Government is awaited.

18. Relevant FAQ by IDTC of ICAI-December 2018
Q34 Whether ITC of TRAN-II filed after March-18 will be reported in Table-6L?
Ans. No. ITC of TRAN-II credited in electronic credit ledger up to 31st March 2018 only be reported in Table-6L. Same way any reversal which have impact on electronic credit ledger up to 31st March is to be reported in Table-7G.
TREY
research

19. Declaration of Input Tax Credit (ITC) in GST Annual Return (GSTR 9)

20. Some of very common errors while claiming Input Tax Credit by the Taxpayers
Claiming Excess ITC
Lapse of ITC
Claim of ITC under Wrong Heading
Deposit of RCM but failure to Claim ITC of RCM
Claim of ITC in RCM but failure to pay tax 
Error in Reporting of ITC under Import of Goods/Import of Services/Tax Paid under RCM and reporting under “All Other ITC”.

21. Reporting in Table 6/Table 13
Case 1: Part Credit claimed till March 2018 and Balance till March 2019
X has a credit of Rs 1,50,000 in Books of Accounts. Out of the said credit, he claimed Rs 1,00,000 in GSTR 3B of March Balance Rs 50,000 was claimed in March 2019.
Reporting in Table 6/Table 13
Particulars
Amount
Treatment in Annual Return
ITC Available in Books of Accounts
Rs 1,50,000 –
ITC Claimed in GSTR-3B (July 2017 to March 2018)
Rs 1,00,000
Table 6
ITC Claimed in GSTR-3B – March 2019 (April 2018 to March 2019)
Rs 50,000
Table 13

22. Reporting in Table 8 Particulars Amount Treatment in Annual Return
ITC Claimed in GSTR-3B (July 2017 to March 2018)
Rs 1,00,000
Table 8B
ITC Claimed in GSTR-3B – March 2019
(April 2018 to March 2019)
Rs 50,000
Table 8C

23. Case 2: Part Credit claimed till March 2018 and Part Credit Claimed till March 2019 and Balance could not be claimed
X has a credit of Rs 1,50,000 in Books of Accounts. Out of the said credit, he claimed Rs 1,00,000 till March 2018 and Rs 25,000 in March Balance Rs 25,000 was not at all claimed by X.
 Reporting in Table 6/Table 13
Particulars
Amount
Treatment in Annual Return
ITC Available in Books of Accounts:
Rs 1,50,000 –
ITC Claimed in GSTR-3B (July 2017 to March 2018)
Rs 1,00,000
Table 6
ITC Claimed in GSTR-3B – March 2019
(April 2018 to March 2019)
Rs 25,000
Table 13
ITC Unclaimed
ITC Lapsed

24. Reporting in Table 8 Particulars Amount Treatment in Annual Return
ITC Claimed in GSTR-3B (July 2017 to March 2018)
Rs 1,00,000
Table 8B
ITC Claimed in GSTR-3B –
March 2019
(April 2018 to March 2019)
Rs 25,000
Table 8C
ITC Unclaimed
Table 8E

25. Case 3: Part Reversal Made till March 2018 and Part Reversal made till March 2019
Mr. PQR had reversed ITC of Rs 50,000 in Books of Accounts on account of Rule 42 and Rule 43. However, he could only reverse ITC of Rs 25,000 till March 2018 and balance ITC of Rs 25,000 was reversed in returns of October 2018.
Reporting in Table 7/Table 12
Particulars
Amount
Treatment in Annual Return
Total ITC Reversed in Books of Accounts
Rs 50,000 –
ITC Reversed in GSTR-3B (July 2017 to March 2018)
Rs 25,000
Table 7C/D
ITC Reversed in GSTR-3B –
October 2018
(April 2018 to March 2019)
Table 12

26. Reporting in Table 8 Particulars Amount Treatment in Annual Return
ITC Reversed in GSTR-3B (July 2017 to March 2018)
Rs 25,000
Not to be entered in Table 8
ITC Reversed in GSTR-3B – October 2018
(April 2018 to Sep 2018)

27. Case 4: Part Reversal Made till March 2018 and Part Reversal made till March 2019 and Balance Reversal could not be made till Filing of Annual Return
Alladin reversed ITC of Rs 1,00,000 in Books of Accounts on account of non payment for more than 180 days (Rule 37). However, he could only reverse ITC of Rs 25,000 till March 2018 and Rs 25,000 was reversed in May He could not reverse balance ITC of Rs 50,000 and wants to reverse it in Annual Return.
Reporting in Table 7/Table 12
Particulars
Amount
Treatment in Annual Return
Total ITC Reversed in Books of Accounts
Rs 1,00,000 –
ITC Reversed in GSTR-3B (July 2017 to March 2018)
Rs 25,000
Table 7
ITC Reversed in GSTR-3B –
May 2018
(April 2018 to Sep 2018)
Table 12
Balance ITC to be Reversed
Rs 50,000
Table 7 and Pay by DRC-03 in cash

28. Reporting in Table 8 Particulars Amount Treatment in Annual Return
ITC Reversed in GSTR-3B (July 2017 to March 2018)
Rs 25,000
Not to be reflected in Table 8
ITC Reversed in GSTR-3B –
May 2018
(April 2018 to Sep 2018)
Balance ITC to be Reversed
Rs 50,000

29. Treatment in Annual Return Total IGST Paid on Import
Case 5: In correct Reporting of IGST Paid on import of Goods under “All other ITC”
X had imported goods and paid IGST of Rs 1,00,000/-. He had other ITC of Rs 50,000/-. While filing GSTR-3B, he inadvertently reflected entire ITC in “All other ITC” in Column 4(A)(5) of GSTR-3B. Can he show such amount correctly in GSTR-9.
Reporting in Table 6
Particulars
Amount
Treatment in Annual Return
Total IGST Paid on Import
Rs 1,00,000
Table 6E
All Other ITC
Rs 50,000
Table 6B
Aggregate ITC
Rs 1,50,000

30. Treatment in Annual Return Total IGST Paid on Import
Reporting in Table 8
Particulars
Amount
Treatment in Annual Return
Total IGST Paid on Import
Rs 1,00,000
Table 8H
All Other ITC
Rs 50,000
Table 8B

31. Case 6: Higher Credit claimed in GSTR-3B and Part Wrong availment adjusted till March 2018, Part Adjusted in June Part could not be adjusted till filing of Annual Return (Reversal has been made through Table 4(B)(2) of GSTR-3B)
X had Input Tax Credit Books of Accounts of Rs 1,50,000/-. He inadvertently claimed credit of Rs 15,00,000/-. Out of which Rs 10,00,000/- was reversed till March Rs 2,00,000/- was reversed in June (Reversal has been made through Table 4(B)(2) of GSTR-3B.). Balance Rs 1,50,000/- could not be reversed. .
 Reporting in Table 6/Table 7/Table 13
Particulars
Amount
Treatment in Annual Return
ITC claimed in GSTR-3B
Rs 15,00,000
Table 6B
ITC Reversed during July 17 to March 2018
Rs 10,00,000
Table 7H
ITC Reversed – June 2018
April to March 2019
Rs 2,00,000
Table 13
Balance ITC to be reversed
Rs 1,50,000

32. PROBLEM:::::
It would be worthwhile to mention that Figures in Table 6B would auto populated in Table 8B. This would result in incorrect preparation of Table 8. But then the form offers no solution in this respect as any other way of filing the form would result in incorrect preparation of Table 9. The handbook released by ICAI also provides as follows:
Sl. No. 8B: ITC as per sum total of 6(B) and 6(H)
Notes to consider If ITC is wrongly reported in GSTR-3B, the mistake shall get reflected in this clause

33. Reporting in Table 8
Particulars
Amount
Treatment in Annual Return
ITC claimed in GSTR-3B (July 17 to March 18)
Rs 15,00,000
Table 8B
ITC Reversed during July 17 to March 2018
Rs 10,00,000
Not to be entered in Table 8
ITC Reversed from April to March 2019
Rs 2,00,000
Balance ITC to be reversed
Rs 1,50,000
Alternate Approach: There might be an alternative view of showing the ITC in Table 6B as Rs 3,50, and consequently in Table 8B and Rs 2,00,000 in Table 12. (Though it might not appear proper on an overall view of the form as all reversal made have to be reported in Table 7).
Professional Judgment would be required to be exercised in the matter.

34.  Case 7: Higher Credit claimed in GSTR-3B and Part Wrong availment adjusted till March 2018, Part Adjusted till September 2018 and Part could not be adjusted till filing of Annual Return (Reversal has been made through netting off subsequent credits in Table 4(A)(5) of GSTR-3B)
X had Input Tax Credit Books of Accounts of Rs 1,50,000/- He inadvertently claimed credit of Rs 15,00,000/- due to typing error. Out of this excess Rs 10,00,000/- was reversed till March Rs 2,00,000/- was reversed in September 2018 and Balance Rs 1,50,000/- could not be reversed. Reversal has been made by reducing subsequent Input credits in Table 4(A)(5) i.e. “All Other ITC”

35. Reporting in Table 6/Table 7/Table 13
Particulars
Amount
Treatment in Annual Return
ITC claimed in GSTR-3B (July 17 to March 18)
Rs 5,00,000
Table 6B
ITC Reversed - Sep 18
April 2018 to March 2019
Rs 2,00,000
Table 13
Balance ITC to be reversed
Rs 1,50,000
Table 7H
Reporting in Table 8
Particulars
Amount
Treatment in Annual Return
ITC claimed in GSTR-3B (July 17 to March 18)
Rs 5,00,000
Table 8B
ITC Reversed - Sep 18
April 2018 to March 2019
Rs 2,00,000
Not to be entered in Table 8
Balance ITC to be reversed
Rs 1,50,000

36. ITC as per Books of Accounts Reporting in GSTR-3B in Table 4(A)(5)
 Case 8: Amount shown in GSTR-3B under “All other ITC” as net of Reversal
X had an input of Rs 1,50, and had to reverse credit another credit of Rs 10, (non-payment of consideration for 180 days – Rule 37). He had reflected net credit of Rs 1,40, in GSTR-3B in Column 4(A)(5). How same should be reflected in GSTR-9?
 Reporting Made in GSTR-3B
Particulars
Amount
ITC as per Books of Accounts
Rs 1,50,000
Reversal to be made
Rs 10,000
Reporting in GSTR-3B in Table 4(A)(5)
Rs 1,40,000

37. Ideal Reporting in GSTR-3B
Particulars
Amount
Reporting in GSTR-3B in Table 4(A)(5)
Rs 1,50,000
Reversal in Table 4B(2)
Rs 10,000
Reporting in Table 6 and 7 in GST Annual Return
Particulars
Amount
Treatment in Annual Return
ITC as per Books of Accounts
Rs 1,50,000
Table 6B
ITC Reversed
Rs 10,000
Table 7A

38.  Case 9: RCM Liability Short Paid till September 2018 and balance paid with Annual Return
 X had a liability to pay RCM of Rs 10,00,00/- Out of the said liability, he paid Rs 50,000/- till March 2018, Rs 25,000 till April to March 2019 and Rs 25,000 liability was paid through Annual Return GSTR 9.
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid and availed till March 2018
50,000
Table 4G
Table 6C/6D
RCM Paid and availed from April 18 to March 2019
25,000
Table 10 (Payment in Table 14)
Table 13 (Can it be claimed in R9 of or will it be claimed in R9 of )
RCM Liability Paid in Annual Return
Table 4G with DRC 03 in cash
Lapsed

39.  Case 10: RCM Liability Paid till March 2018 but availed till September 2018
X had a liability to pay RCM of Rs 1,00, He paid entire amount till March 2018 but claimed Input Tax credit of Rs 50,000 only till March 2018 and balance Rs 50,000 was claimed in September 2018.
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid till March 2018
1,00,000
Table 4G NA
RCM availed from July 2017 to March 2018
50,000
Table 6C/6D
RCM availed –
September 2018
(April to March 2019)
Table 13 (Can it be claimed in R9 of or will it be claimed in R9 of )

40. Case 11: RCM Liability Paid in July 2017 but differential tax paid and credit availed in March 2018
X had a liability to pay RCM of Rs 1,00, in July He paid entire amount in July 2017 and claimed credit of Rs 1,00,000. He came to know that he had deposited short tax of Rs 50, because he had deposited 5% instead of 18%. He deposited the additional tax and claimed credit in March 2018.
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid in July 2017
1,00,000
Table 4G
Table 6C/6D
Additional RCM on the above transaction paid in March 2018
50,000
Table 4K

41. Case 12: RCM Liability Paid in till March 2018 but credit reversed due to wrong availment of Credit till March 2018
M/s ABC had a liability to pay RCM of Rs 1,00, in July They paid entire amount in July 2017 and claimed credit of Rs 1,00, Thereafter they realized that out of the same, there was ineligible credit in terms of 17(5) of Rs 50,000 and they reversed the same in GSTR 3B of March 2018.
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid in July 2017
1,00,000
Table 4G
Table 6C/6D
Reversal of Ineligible Credit
50,000 –
Table 7E

42. Case 13: RCM Liability Paid in till March 2018 but credit reversed due to wrong availment of Credit in September 2018
M/s ABC had a liability to pay RCM of Rs 1,00, in July They paid entire amount in July 2017 and claimed credit of Rs 1,00, Thereafter they realized that out of the same, there was ineligible credit in terms of 17(5) of Rs 50,000 and they reversed the same in GSTR 3B of October 2018.
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid in July 2017
1,00,000
Table 4G
Table 6C/6D
Reversal of Ineligible Credit – October 2018
50,000 –
Table 12

43. Case 14: RCM Liability Paid in till March 2018 but credit reversed due to wrong availment of Credit in Annual Return
M/s ABC had a liability to pay RCM of Rs 1,00, in July They paid entire amount in July 2017 and claimed credit of Rs 1,00, Thereafter they realized that out of the same, there was ineligible credit in terms of 17(5) of Rs 50,000 and they intend to reverse the same in GSTR 9 of ?
Particulars
Amount
Treatment in Annual Return (Outward Liability)
Treatment in Annual Return (ITC Claim)
RCM Paid in July 2017
1,00,000
Table 4G
Table 6C/6D
Reversal of Ineligible Credit
50,000 –
Table 7E with DRC-03 in cash

44. TRAN-1 CREDIT Reversed till March 2018
Case 15: TRAN-1 Credit Claimed and Part Credit Reversed till March 2018
X had claimed TRAN-1 Credit of Rs 1,50, against TRAN-1 filed on 26th October Against the said credit, X reversed credit of Rs 50, vide GSTR-3B for the month of March 2018.
Particulars
Amount
Table
TRAN-1 Credit claimed
Rs 1,50,000
Table 6K
TRAN-1 CREDIT Reversed till March 2018
Rs 50,000
Table 7F

45. TRAN-1 CREDIT Reversed in September 2018
Case 16: TRAN-1 Credit Claimed and Part Reversed till September 2018
X had claimed TRAN-1 Credit of Rs 1,50, against TRAN-1 filed on 26th October Against the said credit, X reversed credit of Rs 50, in books of accounts for but reported vide GSTR-3B for the month of September 2018
Particulars
Amount
Table
TRAN-1 Credit claimed
Rs 1,50,000
Table 6K
TRAN-1 CREDIT Reversed in September 2018
Rs 50,000
Table 12

46. TRAN-1 CREDIT Reversed with Annual Return
Case 17: TRAN-1 Credit Claimed and Part Reversed in Annual Return
X had claimed TRAN-1 Credit of Rs 1,50, against TRAN-1 filed on 26th October Against the said credit, X reversed credit of Rs 50, in Annual Return.
Particulars
Amount
Table
TRAN-1 Credit claimed Rs
Table 6K
TRAN-1 CREDIT Reversed with Annual Return
Rs 50,000
Table 7F with DRC-03
However, it is advised that in view of the Circular No. 58/32/2018 dated 4th September 2018 as amended vide Circular No. 88/07/2019 Dated 1st February 2019, Reversal of Excess Credit through GSTR-3B is no longer available and it has to be through DRC-03 in cash only selecting Section 73/74 of CGST Act, 2017.

47. It may be noted that all such liabilities may be discharged by the taxpayers, either voluntarily in FORM GST DRC-03 or may be recovered vide order uploaded in FORM GST DRC-07, and payment against the said order shall be made in FORM GST DRC-03. It is further clarified that the alternative method of reversing the wrongly availed CENVAT credit under the existing law and inadmissible transitional credit through Table 4(B)(2) of FORM GSTR-3B would no longer be available to taxpayers. The applicable interest and penalty shall apply in respect of all such amounts, which shall also be paid in FORM GST DRC-03.”

48. Case 18: TRAN-1 Credit Claimed and TRAN-1 Revised till 27th December 2017
X had claimed TRAN-1 Credit of Rs 1,50, against TRAN-1 filed on 26th November Against the said credit, X filed revised TRAN-1 on 25th December 2017 availing a net credit of Rs 1,00,
Particulars
Amount
Table
TRAN-1 Credit claimed
Rs 1,00,000
Table 6K

49. Not Relevant as it would form part of R9 for FY 2018-19.
Case 19: Manual TRAN-1 Credit Claimed in Return filed for the month of April 2018
X had claimed Manual TRAN-1 Credit of Rs in pursuance of High Court Order in the return filed for the month of April 2018.
Particulars
Amount
Table
TRAN-1 Credit claimed
Rs 1,00,000
Not Relevant as it would form part of R9 for FY

50. CGST and SGST Credit reversed IGST Credit claimed till March 2018
Case 20: ITC Claimed in Wrong Head but reversed and reclaimed till March 2018
X had paid Rs in IGST but inadvertently credit was claimed as Rs each in both CGST and SGST. He reversed the credit under CGST and SGST till March 2018 through Column 4(B)(2) of GSTR-3B and claimed correct credit in IGST in March 2018.
Particulars
Amount
ITC Claimed-Table
ITC Reversed Table
CGST and SGST Credit
200000
Table 6B NA
CGST and SGST Credit reversed
Table 7H
IGST Credit claimed till March 2018
100000

51. CGST and SGST Credit reversed IGST Credit claimed till March 2019
Case 21: ITC Claimed in Wrong Head but reversed and reclaimed in September 2018
X had paid Rs in IGST but inadvertently credit was claimed as Rs each in both CGST and SGST in March He reversed the credit under CGST and SGST till March 2019 and claimed correct credit in IGST in March 2019.
Particulars
Amount
ITC Claimed-Table
ITC Reversed Table
CGST and SGST Credit
200000
Table 6B NA
CGST and SGST Credit reversed
Table 12
IGST Credit claimed till March 2019
100000
Table 13

52. CGST and SGST Credit reversed Table 7H with DRC-03 in cash
Case 22: ITC Claimed in Wrong Head but reversed with Annual Return
X had paid Rs in IGST but inadvertently credit was claimed as Rs each in both CGST and SGST in March He wants to reverse the credit under CGST and SGST in Annual Return.
Particulars
Amount
ITC Claimed-Table
ITC Reversed Table
CGST and SGST Credit
200000
Table 6B NA
CGST and SGST Credit reversed
Table 7H with DRC-03 in cash
IGST Credit remaining
100000
Lapsed

53. Reasons for non reconciliation of ITC availed in GSTR 3B and ITC shown in GSTR 2A
IGST claimed on import of goods and/ or services
GST paid on RCM basis for which Input availed
Transitional Credit claimed in TRAN 1 and TRAN 2
ITC for goods and/ or services received in but ITC availed in
ITC for goods and/ or services supplied by supplier in but received by recipient in , hence, ITC availed in
Supplier issued debit note/ credit note in , but recipient not aware and did not pass entries in books of accounts and also did not reflect in GSTR 3B
Supplier did not file GSTR 1

54. TREATMENT OPTIONS ????
CONSEQUENCES ????
POSSIBLE ISSUES ????

55. For Patient listening
With regards: CA. Raginee Goyal, FCA, DISA (ICAI)