Whether GSTN Advisory for Table 8C of GSTR-9 is wrong ?

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As the due date for GSTR-9 and GSTR-9C is approaching fast, professionals are struggling with the filing task.

Generally, Advisories are issued by GSTN to ease out the professionals confusion and difficulty. But recently an Advisory has been issued by GSTN regarding Table 8C of GSTR-9, which has added worries to professionals job.

This advisory has been issued regarding Table 8C of GSTR-9.

Background:

As you aware, Form FY 2023-24 Table 8A of GSTR-9 has been changed to be auto-populated from GSTR-2B instead of GSTR-2A. Earlier this table (8A) was being auto-populated from GSTR-2A.

So professionals were asking for clarification regarding treatment of Table 8C after above change.

Table 8C deals with ITC on inward supplies received during the financial year but availed in the next financial year up to specified period.

Issue:

The main issue of confusion is that since Table 8A of GSTR-9 has been auto-populated on the basis of taxpayer's GSTR-2B instead of GSTR-2A. And GSTR-2B does not include invoices reported by supplier after March 2024 for FY 2023-24. So whether ITC related to such invoices should be ignored for Table 8C.

Taxpayers were expecting a clarification that such ITC should not be reported in Table 8C because including these ITC and invoices will result in Negative amount in Table 8D.

Checkout the below example. 

Advisory:

But to everyone surprise, an advisory has been issued by GSTN that such ITC is still to be reported in Table 8C. The advisory takes reference from the instructions mentioned in the GSTR-9 Form.

Although both GSTR-9 instructions and advisory says that such ITC should be reported in Table 8C, but none of these clarifies as to what will happen to the negative amount being reported in Table 8D?

Advisory does not clarify or assure taxpayers that they will not get any notice for reporting negative ITC in Table 8D because a negative amount in Table 8D simply shows that taxpayer has over claimed his ITC as compared to GSTR-2B?

Recommendation:

So in our considered view, taxpayer may ignore such ITC for Table 8C to avoid ended up reporting negative balance in Table 8D, till a further clarification is issued by GST department.

Like every year, we have prepared a manual for GSTR-9 and GSTR-9 based on the updated instructions which you can download from below links.

Disclaimer: The views expressed above are author's view. Taxpayers are advised to use their legal prudence while filing GSTR-9.

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