The Goods and Services Tax Network (“GSTN”) has issued an Advisory dated 17th October 2021 for Taxpayers regarding the availability of Input Tax Credit for Financial year 2020-21.
As per Section 16(4) of CGST Act, 2017, no taxpayer shall take input tax credit in respect records (invoices and debit notes) for supply of goods or services (or both) for Financial Year 2020-21 after the due date of furnishing the return for the month of September 2021.
The due date for the GSTR-3B for September 2021 is either 20th October 2021 for monthly filers and 22nd or 24th October 2021 depending on the State/UT of registration of the taxpayer. In view of the same, the following may kindly be noted:-
Records (invoice or debit notes) pertaining to Financial Year 2020-21 reported in GSTR-1 after due date of GSTR-3B of September 2021 will not reflect as:-
A. “ITC Available” in GSTR-2B of the recipients
B. “ITC as per GSTR-2A” in Table-8A of GSTR-9 of the recipients
It is requested that the taxpayers may take note of the above and ensure that their records pertaining to Financial Year 2020-21 are reported on or before the due date of their GSTR-3B for the month September 2021, or for the quarter of July to September 2021 in case of quarterly GSTR-3B filers. Availment of ITC by the recipients contrary to the legal provisions in GST may entail action by the tax administrations in accordance with law.
Necessary Steps to be Taken
Every GST Registered person should ensure filing of GSTR-1 for the month of Sep-21 by the due date to avoid dispute with your buyers.
Every Registered person should reconcile the GSTR-2A along with books of Accounts and identify the ITC not reflecting in GSTR-2A/2B.
After step 2 every registered person should start follow up with the vendors to file all the pending GSTR-1 by due date of GSTR-3B for the month of Sep-21. Otherwise, registered person may face litigation with the department in respect to claim of such ITC.
G Anshul & Co