Difference in GSTR-2A and GSTR 9 annual return
We are in the process of preparing and filing of GSTR 9 annual return for FY 2018-19, and observing difference in input tax credit (ITC) as per consolidated GSTR-2A and table 8A of GSTR-9. Finding the difference and complete reconciliation of the difference we must aware of the reason for difference in GSTR 2A and GSTR 9 annual return.
Here are reasons for difference in GSTR-2A and GSTR 9 annual return:
1. GSTR-1 filed but not submitted by the supplier.
GSTR-2A captures data from saved/submitted/filed GSTR1 by supplier, however Table 8A of GSTR 9 captures data only from filed GSTR 1 by supplier. Sometime suppliers feed data in GSTR-1 but fails to verify GSTR-1 by EVC/DSC. In such case status of GSTR-1 shows as “non-submitted” in GSTR-2A. Such “non-submitted” invoices will not reflected in table 8A.
2.Filing of GSTR-1 by supplier after due date
Figures in Table 8A of FORM GSTR-9 are auto-populated only for those FORM GSTR-1 which were furnished by the corresponding suppliers by the due date. Thus, ITC on supplies made during the financial year 2018-19, if reported beyond the said date by the corresponding supplier, will not get auto-populated in said Table 8A.
Section 16(4) of GCST also impose restriction on availment of ITC beyond last date to file return for September 2019.
3.Place of supply different than your registered State
The invoices for which place of supply is different than state of recipient will not be reflected in Table 8A. Check place of Supply column of GSTR-2A, if invoices having different state than your state you can not avail ITC for such invoices.
4.Invoices in GSTR-2A where Reverse Charge column is marked as “Y”
Invoices & Debit/Credit Notes in GSTR 2A where reverse charge is marked as applicable (Yes) are excluded from Tale 8A of GSTR-9. GST credit for such invoices not available.
5.Composition Scheme
The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.
6. Amendment of invoices
The table 8A of Form GSTR-9 gets only the latest values auto-populated on the basis of Form GSTR-1, after considering all the alterations made. For instance if an invoice with taxable amount of INR 100/- and tax of INR 18/- was filed in Form GSTR-1 in December 2018 but the amount of taxable value was altered to Rs 90 in January 2019, then the Form GSTR-2A of December 2018 will showcase ITC of INR 18 while the Form GSTR-2A of January 2019 will showcase ITC of INR 16.20, and the table 8A of Form GSTR-9 will constitute ITC of INR 16.20 which is the latest value.