ICAI FAQs clarify GSTR-3B ITC reporting for import-service RCM

Aug 11, 2026 | 11:02 AM

GST

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Relief for a reporting error

FAQs attributed to the Institute of Chartered Accountants of India clarify that input tax credit relating to reverse-charge tax on import of services need not be denied merely because the taxpayer reported it in Table 4(A)(3) of Form GSTR-3B, provided the credit is otherwise eligible.

The clarification addresses a classification error within Table 4(A), rather than treating the choice of sub-table as an independent condition governing entitlement to credit. Its practical relevance lies in separating the substantive eligibility of ITC from an incorrect disclosure in the return.

How Table 4(A)(3) operates

Table 4(A)(3) is designated for ITC available on inward supplies liable to reverse charge, other than the categories covered by the preceding two entries. The GST Portal’s official GSTR-3B guidance states that this field is auto-populated from specified sections of Form GSTR-2B on a net basis, after accounting for the relevant invoices, debit notes and credit notes.

The portal guidance also describes GSTR-3B as a simplified summary return through which taxpayers declare and discharge their GST liabilities. Values in the return are auto-populated using suppliers’ Form GSTR-1 or GSTR-1A filings and the system-generated Form GSTR-2B, depending on the relevant table.

What taxpayers should review

The FAQs indicate that an incorrect placement of import-service RCM credit in Table 4(A)(3) does not, by itself, require denial of the ITC. Taxpayers must nevertheless establish that the underlying credit satisfies the applicable eligibility requirements; the clarification does not convert an otherwise ineligible credit into an admissible one.

Businesses and tax teams should therefore distinguish between a disclosure mismatch and a substantive ITC defect when reviewing past GSTR-3B filings or responding to return-based scrutiny. The relevant transaction records, reverse-charge tax payment and basis for claiming the credit should remain capable of reconciliation.

Key takeaway

Eligible ITC on import services should not be denied solely because it was reported under Table 4(A)(3) of GSTR-3B, but taxpayers must still substantiate the underlying eligibility of the credit.