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While paying taxes to the Government, businesses can use the credit of GST paid on the purchases like raw materials/services used for manufacturing or selling products. It is known as an Input tax credit (ITC). If the input tax credit is wrongly claimed, then it should be reversed by making payment to that extent next month.

1. What does reversal of ITC mean?

In certain situations, even if the basic conditions for claiming ITC is satisfied, ITC claimed must be reversed. Reversal of ITC means the credit of inputs utilised earlier would now be added to the output tax liability, effectively nullifying the credit claimed earlier. Depending upon when such reversal is done, payment of interest may also be required. 

2. Specific conditions for ITC reversal

The ITC is required to be reversed under various scenarios defined in the Act. Some of those scenarios are summarized below:

 

Circumstances  When is ITC reversal required
The recipient fails to pay consideration to the supplier (whether fully or partly) for a particular supply Within 180 days from the date of issue of invoice
Depreciation under the Income Tax Act has been claimed on the GST component of capital goods purchased Reversal is required at the time of closing Books of accounts for that year
Inputs have been used to make an exempt supply  On a periodic basis (monthly/yearly) using a formula given below for common credits (if inputs are exclusively used for making exempt supply, then reverse it as and when identified to have been claimed)
Inputs have been used for manufacturing supplies some of which were used for non-business purposes On a periodic basis (monthly/yearly) using a formula given below for common credits (if inputs used are exclusively attributable to a supply used for consumption, reverse such ITC upon identifying as having been claimed)
Cancellation of GST registration While filing Form REG-16 under various situations explained in detail here:

cleartax.in/s/cancellation-gst-registration

Reversal of 50% of ITC by banking and other financial companies under special rules At the time of filing regular returns
Reversal of 5/6th of the ITC taken on gold dores in stock as on 01/07/2017 At the time of supply of either the gold dore bar or the gold/gold jewellery 
ITC has been availed on ‘blocked credits’ At the time of filing regular returns upto the date of filing annual return
Inputs used in goods that were lost, destroyed, stolen, etc. At the time of filing the regular returns in relation to the month in which such loss had occurred. 
Inputs used in goods that were given out as free samples At the time of filing the regular returns in relation to the month in which such free samples were given out.

 

3. Calculation of ITC under various rules

Let’s check out the different rules prescribed for calculating amount of ITC to be reversed :

Rule 42 and 43: ITC reversal on the supplies that are exempt or used for personal consumption

Before we proceed to discuss each rule, the total ITC can be divided into the following parts:

  1. Specific credit: ITC that can specifically be attributable to a supply – either taxable, non-taxable, or supply consumed for personal use.

Treatment: Separate such ITC amount from the total ITC since it can be easily identified. 

  • The amount of ITC that is only directly attributable to a particular taxable supply can be utilised. It is available in electronic credit ledger. 
  • Taxpayer must reverse the amount of ITC directly attributable to a particular supply that is non-taxable/used for personal consumption, only when wrongly availed.
  1. Common credit – ITC amount that cannot be attributable to a specific supply but is used for partly making both the taxable and non-taxable supplies/supplies used for personal consumption. 

Treatment: 

  • Taxpayer must identify and reverse the proportionate ITC amount to the extent of supplies that are non-taxable/used for personal consumption.
  • The remaining ITC left is eligible for claim.

The calculation differs for:

  1. a) Inputs or input services- covered by rule 42
  2. b) Capital goods- covered by rule 43

Rule 42: Reversal of ITC on inputs/input services:

Step-1: Businesses must first segregate the specific credits that are ineligible for claim,  from the total ITC as follows: 

Variable used Formulae / Explanation
T Total input tax paid credit on inputs and input services
T1 Out of ‘T’, the specific credit attributable to inputs/input services intended to be used for non-business purposes
T2 Out of ‘T’, the amount of input tax attributable to inputs/input services intended to be used exclusively for effecting exempt supplies
T3 Out of ‘T’, the amount of input tax deemed as ‘blocked credits’ under section 17(5)
Note: T1, T2, and T3 must be reported in GSTR 3B at summary level for every tax head

 

Step-2: Reduce T1, T2 and T3 from the total ITC and derive the common credit as follows:

 

C1 ITC credited to electronic credit ledger

T – (T1 + T2 + T3)

T4 Specific credit on inputs/input services attributable exclusively for making taxable supplies. This would also include zero-rated supplies like exports and supplies to SEZ.
C2 Common credit

C1 – T4
ITC on the inputs that is assumed to have been used partly in making taxable supplies and partly in making exempt supplies or used for a non-business purpose. 

 

Step-3: Compute the amount of ITC to be reversed out of the common credit as follows:

D1 The ITC attributable towards exempt supplies out of common credit:

(E÷F) × C2
Where:

E: Aggregate value of exempt supplies during the tax period

F: Total turnover in the State of the registered person during the tax period
Note: For building construction services, (E÷F) will be calculated on a project-basis where: 

-E stands for aggregate carpet area of exempt construction project or apartments sold after construction is over

-F stands for aggregate carpet area of the apartments in the project 

D2 Deemed to be ITC attributable for non-business purposes out of common credit:
5% of C2
C3 Remaining eligible ITC out of common credit:
C2 – (D1 + D2)

 

Based on the above calculations, D1 and D2 will be the ITC that needs to be reversed. 

Illustration: 

Consider the following scenario for the month of July, 2019 in relation to supplies made in Karnataka: Total ITC available (T) = Rs. 1,50,000; ITC on inputs attributable to supply used by Director for personal use (T1): Rs. 7,500; ITC on inputs to be used exclusively for making exempt supply (T2): Rs. 15,000; Blocked credits (for example, GST portion paid in respect of taxi service obtained) (T3): Rs. 4,500; ITC on inputs used exclusively for making taxable supplies (T4): Rs. 1,05,000; Aggregate value of exempt supplies made in July (E): Rs. 2,25,000; Total turnover in Karnataka (F): Rs. 30,00,000; 

Solution:

C1 = T – (T1+T2+T3); 

C1 = 1,50,000 – (7,500+15,000+4,500)

⸫ C1 = 1,23,000

The common credit C2 = C1 – T4

C2 = 1,23,000-1,05,000

⸫ C2 = 18,000

D1 = (E÷F) × C2

D1 = (2,25,000 ÷ 30,00,000) × 18,000

⸫ D1 = 1,350

D2 = 5% of C2

⸫ D2 = 900

C3 = C2 – (D1 + D2)

⸫ C3 = 15,750

So, out of the originally available ITC of Rs. 1,50,000, only C3 (Rs. 15,750) and T4 (Rs. 1,05,000) were credited ultimately to the electronic credit ledger and D1 (Rs. 1,350) and D2 (Rs. 900) were required to be reversed.

Rule 43: Reversal of ITC on capital goods:

The first step is to find out if the ITC falls under the following criteria:

  1. The ITC is in relation to capital goods that have been used exclusively for non-business purposes or for making exempt outward supplies. OR
  2. The ITC is in relation to capital goods that have been used exclusively for making supplies other than exempt supplies. Note that this would include zero rated supplies too.

In case the ITC falls under category ‘A’ above, then credit will not be allowed in respect of the same. 

In case the ITC falls under category ‘B’ above, then credit will be allowed and taken to Electronic Credit Ledger. 

The useful life of capital goods are taken to be five years from the date of invoice. This is done so that in case the capital goods were covered in category ‘A’ or ‘B’ as mentioned earlier and are now not covered under either category, then the ITC would be called ‘common credit’ or ‘Tc’ and 5% would have to be deducted from this common credit for every quarter or part quarter for the time it was covered in the category ‘A’ or ‘B’. 

The useful life of the capital goods have been taken as 5 years, but our filing period relates to the supplies made/received in a particular month, so we will first find the ITC attributable to a month by dividing the credit by 60.

 

Variable used Formulae / Explanation
Tm Tc ÷ 60

Amount of ITC attributable to a tax period (a month) on common capital goods during their useful life

Tr Aggregate Tm of all those capital goods which have useful life remaining at the beginning of the tax period
Te This is the common credit attributable towards exempted supplies, which is calculated as follows:
(E ÷ F) × TrWhere:

E: Aggregate value of exempt supplies made during the tax period

F: Total turnover in the State of the registered person during the tax period
Note: For building construction services, (E÷F) will be calculated on a project-basis where: 

-E stands for aggregate carpet area of exempt construction project or apartments sold after construction is over

-F stands for aggregate carpet area of the apartments in the project 

 

Thus, Te calculated above will be the ITC in respect of capital goods that is required to be reserved or added to the output tax liability. Note that the above calculations would slightly differ if the supply is in the nature of services covered under Paragraph 5(b) of Schedule II of the CGST Act.

Illustration:

A company operating in Karnataka had availed the following ITC on various capital goods purchased in the month of July, 2019:

ITC on Machine A (used exclusively in supply of exempt goods): Rs. 1,50,000

ITC on Machine B (used exclusively in supply of taxable goods): Rs. 9,00,000

ITC on Machine C (used exclusively for non-business purposes): Rs. 20,000

ITC on Machine D (used partly in supply of taxable and exempt goods): 4,50,000

The company had also made the following type of output supplies in Karnataka in the month of July:

Turnover in relation to exempt supplies: Rs. 20,00,000

Turnover in relation to taxable supplies: Rs. 80,00,000

Solution:

ITC on machine A and C will not be credited to the electronic credit ledger (1,50,000+20,000 = 1,70,000).

ITC on machine B will be credited to the electronic ledger: Rs. 9,00,000

ITC on machine D will also be credited to the electronic credit ledger: Tc = 4,50,000 

Tm = Tc ÷ 60 = 7,500 which is also Tr in this case.

The amount of ITC to be reversed for the month of July, 2019 would be:

= (E ÷ F) × Tr

= (20,00,000 ÷ 80,00,000) × 7,500 = 1,875

Thus total ITC credited to electronic ledger for the month of July, 2019 = Rs. 10,70,000 and

Total ITC reversed for the month of July, 2019 = Rs. 1,875

 

Rule 44: Reversal of ITC in case of cancellation of GST registration or switches to composition scheme:

The aim of this rule is to reverse all the ITC that has been availed by a registered person in the event that he chooses to pay tax under the composition scheme or his registration gets cancelled for any reason. The calculation is done as follows:

  1. For inputs held in stock or contained in semi-finished goods and finished goods in stock, the ITC must be reversed is calculated proportionate to corresponding invoices on which credit was taken. Thus ITC will be allowed only upto the time the registered person switches to composition scheme or on cancellation of registration.
  2. In case of capital goods, ITC availed will be based on the useful life (in months) and shall be computed on a pro-rata basis. Thus ITC for the remaining useful life of the asset must be reversed while switching over to composition scheme or on cancellation of registration.
  3. Finalised-ITC-reversal-under-GST-

Rule 44A: Balance transitional ITC to be reversed on 1st July 2017 for gold dore bar

This rule relates to ITC taken under the transitional provisions of the CGST Act. It is based on CENVAT credit available under the earlier scheme of taxation in respect of additional duty of customs (section 3(1) of the Customs Tariff Act, 1975) paid for importation of gold dore bar.

Where stock of such gold dore bar (raw material) or gold jewellery (final product) lies with the taxpayer on 1 July, 2017, the ITC will be restricted to 1/6th of the credit availed in respect of such gold dore bar. Hence, 5/6th of the credit availed must be reversed at the time of supply of either the gold dore bar or the gold/gold jewellery made out of it. 

4. Reporting of ITC reversal in GSTR-3B

The amount of ITC reversal needs to be calculated by the taxpayer himself and filled up in Table 4B of GSTR-3B. The ITC reversed that needs to be reported is of two types – 

  1. ‘As per rule 42 & 43 of CGST/SGST Rules’, where the ITC attributable to exempt or non-business supply is required to be calculated by us using the formula mentioned earlier and entered in this field – thus this field will not be auto-populated; and
  2. ‘Others’, where ITC reversal due to other circumstances will have to be reported; 

5. Reporting of ITC reversal in GSTR-9

GSTR-9 (annual return) will also need to be filled up with details regarding ITC reversed for the whole year. Wherever possible, the details will be auto-filled on the basis of the data entered in the monthly Form GSTR 3B but changes can be made by the taxpayer wherever required. Table 7 contains the details of ITC reversed and ineligible ITC for the financial year. The relevant details need to be provided for the whole year accordingly. 

6. How can ClearTax help?

The process of calculation of the reversal ITC and reporting of the same in the relevant GST returns can be made simpler by trying out the smart calculator feature while filing GSTR-9 provided by ClearTax GST. It downloads entire year’s data from GSTN easily to file an accurate GSTR-9 and comes with intelligence to reconcile between GSTR-1-GSTR-3B-Books of accounts to give suggestions for fixing mismatches.

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