Budget 2021 update :Section 16 amended to allow taxpayers’ claim of the input tax credit based on GSTR-2A and GSTR-2B. Henceforth, the input tax credit on invoice or debit note may be availed only when the details of such invoice or debit note have been furnished by the supplier in the statement of outward supplies and such details have been communicated to the recipient of such invoice or debit note.
GSTR-3B vs GSTR-2A is an important exercise that businesses must not miss out. It helps businesses claim the full Input tax credit (ITC) and also reverse any excess ITC claimed. In turn, the reconciliation before filing GSTR-3B will help avoid any potential demand notices from the tax authorities.
Form GSTR – 3B is a monthly summary return filed by the taxpayer by the 20th of the next month. Taxpayers are allowed to take the input tax credit (ITC) based on the details declared by the taxpayer in Table 4 of Form GSTR – 3B:
Form GSTR – 2A is an auto-populated form generated in the recipient’s login, covering all the outward supplies (Form GSTR – 1) declared by his suppliers.
Update as on 22nd December 2020
1. Following are the changes in Rule 36(4) from 1st January 2021:
- The ITC shall be available as per the invoices uploaded by respective suppliers either in their GSTR-1 or by using the Invoice Furnishing Facility (IFF).
- The recipients can claim provisional input tax credit in GSTR-3B to the extent of 5% instead of earlier 10% of the total ITC available in GSTR-2B for the month.
2. Certain taxpayers cannot make payment from their electronic credit ledger in excess of 99% of the total tax liability for the tax period as per a new rule 86B.
Latest update as on 30th June 2020
The maximum late fee to be capped at Rs 500 per return, for the tax periods given below, filed after the deadlines given in notification 52/2020 (as listed in the below at sl.no. 2 dated 24th June 2020) but before 30th September 2020, whereas nil return to not be charged any late fee.
1. For turnover more than Rs 5 crore: May 2020 – July 2020
2. For turnover equal to or below Rs 5 crore: February 2020 – July 2020
Latest update as on 24th June 2020
1. The CBIC has waived/reduced late fees for the late filing of GSTR-3B returns for the period July 2017 to January 2020, as follows-
a) If GST liability is Nil, and the GSTR-3B return is filed between 1st July, 2020 and 30th September, 2020, then the amount of late fees stands waived.
b) If the GST liability is not Nil, and the GSTR-3B return is filed between 1st July, 2020 and 30th September, 2020, then the amount of late fees stand waived in excess of Rs.250* under the CGST Act.
*Rs.500 will be the total amount payable, Rs.250 under CGST and Rs.250 under SGST.
- The CBIC has notified the due dates applicable, with regard to interest and late fees for filing GSTR-3B. Here is a list of the notified dates from February to August 2020:
|Annual Turnover in the Previous FY
|| Due date
||Last date without late fee or interest, as applicable
|More than Rs.5 crore
||20th Mar 2020
||24th Jun 2020*
||20th Apr 2020
||20th May 2020
||27th Jun 2020^^
||27th Jun 2020@
||20th Jul 2020
||20th Jul 2020@
||20th Aug 2020
||20th Aug 2020@
||20th Sept 2020
||20th Sept 2020
|Up to Rs. 5 crore in category A# States/UTs
||22nd Mar 2020
||30th Jun 2020^
||22nd Apr 2020
||3rd Jul 2020^
||22nd May 2020
||6th Jul 2020^
||12th Jul 2020
||12th Sept 2020^
||22nd Jul 2020
||23rd Sept 2020^
||22nd Aug 2020
||27th Sept 2020^
||1st Oct 2020**
||1st Oct 2020
|Up to Rs. 5 crore in category B## States/UTs
||24th Mar 2020
||30th Jun 2020^
||24th Apr 2020
||5th July 2020^
||24th May 2020
||9th July 2020^
||14th Jul 2020
||15th Sept 2020^
||24th Jul 2020
||25th Sept 2020^
||24th Aug 2020
||29th Sept 2020^
||3rd Oct 2020**
||3rd Oct 2020
|#Category A: Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union Territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands and Lakshadweep.
##Category B: Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, the Union Territories of Jammu and Kashmir, Ladakh, Chandigarh and Delhi.
*No interest charged if GST dues are paid before 4th Apr, 5th May and 4th Jun for Feb, Mar & Apr respectively. But, interest applies from the 16th day at a reduced rate of 9% p.a. up to the date of actual payment, if paid before 24th Jun 2020. If not, then interest is charged in a staggered manner as given above plus interest at 18% p.a. will apply from the next day after 24th Jun 2020 up to the actual date of filing. In that case, a late fee will apply from the due date until the actual date of filing.
@If filed afterwards but before 30th September 2020, the maximum late fee of Rs 500 per return shall be charged vide CGST notification number 57/2020 dated 30th June 2020.
^^The due date was extended via CGST notification no. 36/2020 dated 3rd Apr 2020.
^Thereafter, a reduced interest rate at 9% p.a. will apply if taxpayer files on or before 30th Sept 2020. If not, then interest applies in a staggered manner as given above plus interest at 18% p.a. will apply from the next day after 30th Sept 2020 up to the actual date of filing. In that case, a late fee will apply from the due date until the actual date of filing.
**The due date was extended via CGST notification no. 54/2020 dated 24th Jun 2020.
Update as on 8th June 2020
A nil GSTR-3B can be filed via SMS using the registered mobile number and OTP verification. The CBIC has notified the date of applicability as 8th June 2020,
from which nil returns can be filed through SMS.
Update as on 3rd April 2020
The CBIC has notified that taxpayers can claim input tax credit in the GSTR-3B return from February 2020 to August 2020, without applying the rule of capping provisional ITC claims at 5% (10% upto 31st Dec 2020) of the eligible ITC as per GSTR-2B (Was GSTR-2A upto July 2020).
While filing the GSTR-3B of September 2020, the taxpayers must cumulatively adjust ITC as per the above rule from February 2020.
GSTR-3B vs GSTR-2A
When the supplier files GSTR – 1 in any particular month disclosing his sales, the corresponding details are captured in GSTR – 2A of the recipient.
While the filing of Form GSTR – 2 has been kept in abeyance, it is still important under the GST framework for the taxpayers to reconcile the ITC claimed in Form GSTR – 3B and Form GSTR – 2A.
GSTR – 3B is a summary return. Hence, the amount of ITC available as disclosed in Table 4(a) must match with tax details disclosed in Form GSTR – 2A.
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 – 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.
Use the GST Health check
tool to identify the differences between the GSTR-3B and GSTR-2A.
Reconciliation at the time of filing of Annual return:
Even at the time of filing an Annual return in Form GSTR – 9, reconciliation of ITC as per GSTR – 3B and GSTR – 2A is required to be done in Table 6 and Table 8 across months.
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:
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.
- 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 2017 – 18 but availed in FY 2018 – 19.
After Identifying mismatches by GSTR-2A vs GSTR-3B
After considering the situations mentioned above, if any discrepancies are found in Form GSTR – 2A and GSTR -3B leading to any excess ITC claimed by the recipient, the same must be paid by the taxpayer along with interest.
It is, therefore, necessary that this reconcile exercise is done on a regular basis to ensure that only bonafide input tax credit is claimed.
How can ClearTax GST help you?
ClearTax GST offers easy import and download of GST data for preparation of GST returns.
It provides various options for a user to ingest data to prepare the GSTR-1, GSTR-3B or GSTR-4 in under minutes. Options like excel ingestion or direct integration with ERP are available for importing sales or purchase data onto the ClearTax GST software.
The best part is, you have to import the sales data for GSTR-1 just once. Based on this, the software auto-populates the details into GSTR-3B in a click of a button. Thus, one can avoid errors and ensure 100% accuracy in reporting of data with minimal manual intervention.
ClearTax GST also provides useful insights under the REPORTS section so you can speed through the journey of GST compliance in a hassle-free way!
Try ClearTax Health Check that offers an all-in-one report of the insights.
Alternatively, the report
of ‘GSTR-3B vs GSTR-2A ITC Comparison Report’
helps you compare GSTR-2A with GSTR-3B.
This report helps you compare the ITC reported in GSTR-3B by you with the ITC reflected on the GSTR-2A.
Further, you can compare the data month-wise or for every financial year. You can also compare data at GSTIN level or cumulatively at PAN level.
Advantages of GSTR-3B vs 2A report
- Download GSTR-2A anytime across months from the GST portal to start comparing with GSTR-3B data. Verify GST login once using OTP, and continue to easily update data in a click, anytime and anywhere.
- Check the difference for every field such as B2B other than reverse charge to compare ITC between GSTR-2A and GSTR-3B.
- ITC comparison at PAN and GSTIN level is available.
- Know the differences instantly at a monthly level or at a quarterly level, to take further action.
How to get GSTR-3B vs GSTR-2A Report?
– Health check Report gives a complete picture of GSTR-3B vs GSTR-2A both at a summary and monthly levels. Follow these simple steps to get a complete GSTR-3B vs GSTR-2A ITC comparison report:
Login to the Cleartax GST Account. Go to the ‘Reports’ section, click on ‘view’ against the ‘Health Check Report’.
Click on ‘Generate Report’ button on the dashboard. You can find that the health check dashboard readily gives the filing status of the GST returns for the GSTIN at a glance.
Verify GSTN credentials using OTP. The OTP is sent to the registered mobile and email with GSTN.
Click on the ‘Download report in excel’ link to download the complete Health check report for your use and to be shared with the team.
Excel report gives the GSTR-3B vs GSTR-2A across different months in a financial year and at a summary level too! Share it across your team and use it to carry out fixes.
You can alternatively
download the ‘GSTR-3B vs GSTR-2A ITC Comparison Report’
report dashboard to get a comparison of data at a glance. Follow the steps as mentioned below:
1. Choose Financial Year
Select the financial year for which you want the report to be generated.
2. Generate Report
If the GSTR-1 and GSTR-3B are both filed using Cleartax GST, then the report is displayed for your use. But if you have not used the software before, just click on the button ‘Refresh Data from GSTN’ appearing on the right-hand side of the report section’GSTIN level’. The yearly return data from GSTN will be fetched after verification via an OTP based on login credentials.
3. Download Report
Notice the difference displayed in the reports section. Click on link ‘Download report as excel’ to use and share the report offline in excel form.
The Health Check Report
also gives you the following results:
Try out the GST health check tool and check your GSTIN’s health now!