GSTR 2A vs GSTR 3B

Before claiming ITC in GSTR 3B, which auto reflected from GSTR 2B, It is essential to reconcile ITC as per GSTR 2B and ITC as per 3B.

Earlier, when GST was introduced, GSTR 2 was the part of the returns to be filed by the taxpayer. Due to some reasons it did not worked out and filing of GSTR 2 kept in abeyance.

GSTR 2A introduced to check if supplier is uploading the invoices.

Since, GSTR 2A reflects the invoices just uploaded by the supplier even though GSTR 1 is not filed, matching ITC of GSTR 2A with ITC claim in GSTR 3B was not as per the section 16.

Therefore, GSTR 2B has been introduced which reflects invoices uploaded in GSTR 1/IFF and GSTR 1/IFF FILED by the supplier before the due date of filing GSTR1/IFF.

Read Difference between GSTR 2A and GSTR 2B

Provide Article link

Hence, after introduction of GSTR 2B, in July-August 2020, matching ITC to be claimed in GSTR-3B with GSTR-2A has now moved to a yearly affair, yet important for TDS and TCS credit.

One of the conditions for claiming ITC in GSTR 3B as per section 16 is, GST must be paid by the supplier.

Supplier must file GSTR 3B of the month in which invoice is issued, before 30th Sept of the next FY as per Rule 37(a) of GST Act.

If supplier does not do so, tax payer has to reverse the ITC of that particular invoice if claimed earlier in the month of issue of invoice.

Therefore, it is important to know if supplier has filed his GSTR 3B before 30th Sept of the next FY.

This information is available in GSTR 2A.

Therefore, Taxpayer must reconcile GSTR 2A with GSTR 3B for each FY after the FY ends. Upon finding the invoice for which GSTR 3B is not filed, taxpayer can send reminder to supplier to file the same and get it filed by the supplier before 30th sept of next FY. (In case the supplier has not recorded the outward supplies in Form GSTR – 1, communication can be sent out to the supplier to ensure that the discrepancies are corrected.)

How to know if supplier has paid GST on your Invoice?

Video

Reasons for non-reconciliation of GSTR-2A vs 3B

The details disclosed in Form GSTR – 2A and Form GSTR – 3B may not reconcile on account of the following reasons:

• The credit of IGST claimed on the import of goods

• IGST Credit on the import of services

• The credit of GST paid on reverse charge mechanism, etc.

• Transitional credit claimed in TRAN – I and TRAN – II.

• ITC for goods and services received in FY 2020-21 but availed in FY 2021-22.

In the cases mentioned above, the figures will not reconcile as no corresponding Form GSTR – 1 is filed by the supplier or the ITC is being claimed at a later date.

Importance for GSTR-3B vs GSTR-2A

It is important to reconcile Form GSTR – 3B and Form GSTR – 2A on account of the following reasons:

• GST authorities have issued notices to a large number of taxpayers asking them to reconcile the ITC claimed in a self-declared summary return Form GSTR – 3B with the auto-generated Form GSTR-2B and Form GSTR – 2A. Such notices are issued in Form GST ASMT – 10. The taxpayer would be required to reply to such notices or pay the differential amount.

• Tax evaders claiming ITC on the basis of fake invoices have also been penalised in the past.

• Reconciliation ensures that credit is being claimed for the tax which has been actually paid to the supplier.

• Ensures that no invoices have been missed/recorded more than once, etc.

• In case the supplier has not recorded the outward supplies in Form GSTR – 1, communication can be sent out to the supplier to ensure that the discrepancies are corrected.

• Errors committed while reporting details in GSTR-1 by suppliers or GSTR-3B by recipients can be rectified.

Disclaimer:- The opinions presented are exclusively those of the author CA Pratibha Varia. The material in this piece is intended purely for informational purposes and for individual, non-commercial consumption. It does not constitute expert guidance or an endorsement by any organization. The author, the organization, and its associates are not liable for any form of loss or harm resulting from the information in this article, nor for any decisions made based on it. Furthermore, no segment of this article or newsletter should be employed for any intention unless granted in written form, and we maintain the legal right to address any unauthorized utilization of our article or newsletter.