Advisory on difference in value of Table 8A and 8C of Annual Returns FY 23-24
According to the latest tax notifications (Notification No. 12/2024-Central Tax dated 10th July 2024 and Notification No. 20/2024-Central Tax dated 8th October 2024), starting from the financial year 2023-24, the total input tax credit (ITC) available for inward supplies will be automatically filled in Table 8A of the GSTR-9 form based on the details in GSTR-2B for that financial year. Additionally, Table 8C will require you to manually enter the value of ITC on supplies received during the year but claimed in the next financial year, up until a specific period.
There have been several inquiries about potential mismatches between the values shown in Table 8A and Table 8C of the GSTR-9 for FY 2023-24. It’s important to note that, for the previous FY (2022-23), Table 8A values were auto-populated from GSTR-2A, but for FY 2023-24, these values are coming from GSTR-2B instead.
As a result, you might notice some differences in how the values appear between the two years. Specifically:
- In Table 8A for FY 2023-24, the values might be higher than expected for FY 2022-23 (because GSTR-2B includes data from both FY 2022-23 and FY 2023-24).
- On the other hand, the values in Table 8A for FY 2023-24 might be lower than expected because they are drawn from GSTR-2B, which may not capture all data for FY 2023-24 by the time it’s auto-populated.
This could lead to a mismatch between Table 8A and 8C in GSTR-9 for FY 2023-24, and is something taxpayers need to be aware of. Few scenarios in this regard are advised hereunder:
| Sr. No. | Issue |
Reporting in GSTR 9 |
| 1 | Invoice having the date of FY 23-24 but the supplier has reported in the GSTR 1 after the due date of March’24. As a result, this amount is not auto populated in the Table 8A of GSTR 9 for FY 2023-24 because it is the part of next years GSTR 2B. How to report such transaction in the GSTR 9 of FY 23-24? | Taxpayer shall report such ITC in the Table 8C and in Table 13 as this is the ITC of FY 2023-24. This is in line with the instructions to the Table 8C and Table 13 of GSTR 9 |
| 2 | Invoice belongs to FY 23-24 and ITC has been claimed in FY 23-24. Due to payment not made to supplier within 180 days, ITC was reversed in 23-24 as per the second proviso to section 16(2) and this ITC is reclaimed in next Year FY 2024-25, after making the payment to supplier. How to report such transaction in the GSTR 9 of FY 23-24? | This reclaimed ITC shall be reported in the table 6H of GSTR 9 for FY 24-25 hence not in the Table 8C and Table 13 of GSTR 9 of FY 2023-24. This is in line with the Instruction to the Table 13 given in the Notified Form GSTR 9. Similar reporting is applicable for the ITC reclaimed as per Rule 37A |
| 3 | Invoice belongs to FY 2023-24 but goods not received in 23-24 therefore ITC is claimed in Table 4A5 of GSTR 3B and reversed in Table 4B2 as per the guidelines of Circular 170 and such ITC reclaimed in next FY 2024-25 till the specified time period. How to report such transaction in the GSTR 9 of FY 23-24? | Taxpayer shall report such reclaimed ITC in the Table 8C and Table 13 as this is the ITC of FY 2023-24. |
| 4 | Invoice belongs to FY 22-23 which is appearing in the Table 8A of GSTR 9 of FY 23-24, as the supplier would have reported the same in GSTR 1 after the due date of filing of GSTR-1 for the tax period of March 23. How to report such transaction in the GSTR 9 of FY 23-24? | This is the ITC of last year (2022-23) and was auto populated in table 8A of GSTR-9 of FY 22-23. Hence, aforesaid value need not to be reported in the table 8C and Table 13 of GSTR-9 for FY 23-24. This is in line with the instruction no 2A given for the notified form GSTR 9 which states that Table 4,5,6 and Table 7 should have the details of current FY only |
| 5 | Where to report the reclaim of ITC for an Invoice which belongs to FY 2023-24, and which is claimed, reversed and reclaimed in the same year? | As already clarified by the CBIC press release 3rd July 2019 in the para k, It may be noted that the label in Table 6H clearly states that information declared in Table 6H is exclusive of Table 6B. Therefore, information of such input tax credit is to be declared in one of the rows only.
Further, as the claim and reclaim is reported only in one row therefore the same should not be reported in the reversal under table 7 of GSTR 9 of FY 23-24. |
Summary of the above advisory is tabulated below:
| Sr. No. | Issue | Reporting in GSTR 9 |
|---|---|---|
| 1 | Invoice dated FY 23-24, reported late after March’24, not auto-populated in Table 8A. | Report ITC in Table 8C and Table 13 for FY 2023-24. |
| 2 | Invoice dated FY 23-24, ITC claimed, reversed due to non-payment, reclaimed in FY 24-25. | Report reclaimed ITC in Table 6H of GSTR 9 for FY 24-25. |
| 3 | Invoice for FY 23-24, goods not received, ITC reversed in FY 23-24, reclaimed in FY 24-25. | Report reclaimed ITC in Table 8C and Table 13 for FY 23-24. |
| 4 | Invoice for FY 22-23, appearing late in Table 8A of FY 23-24. | Do not report in Table 8C or Table 13 of FY 23-24 (belongs to FY 22-23). |
| 5 | Invoice for FY 23-24, claimed, reversed, and reclaimed within the same year. | Report in Table 6H; do not report in Table 7 of GSTR 9 for FY 23-24. |
