All of us, while filing the GSTR 3B for the months of August and September, have observed that the ITC table in the GSTR 3B has changed.
The Government, vide Notification No. 14/2022 – Central Tax dated 5 July 2022, had notified a few changes in Table 4 of Form GSTR‑3B, enabling taxpayers to correctly report information regarding ITC availed, ITC reversal and ineligible ITC in Table 4 of GSTR‑3B.
Those notified changes have now been incorporated into GSTR‑3B and have been available on the GST portal since 1 September 2022.
Comparison of the old and new format of Table 4
There are many points of confusion with respect to this new format for the disclosure of ITC, especially around the transition items. We have summarised the disclosures for a few transactions in the month of August 2022 and for the subsequent periods thereafter.
*** Disclosure in 4D(1) may not be in accordance with the circular. However, the disclosure may be made for the purpose of matching auto‑population with the 4A(5) claim and the 4D(1) disclosure. Hence this disclosure may or may not be done.
What this means in practice
The disclosure methodology has been completely changed, burdening the taxpayer not only to reconcile books with GSTR‑2B, but also to keep track of permanent and temporary reversals — with the added challenge of the time gap between the reflection of invoices in GSTR‑2B and the ITC recorded, or not yet recorded, in the books.
Medium and small‑scale industries that may not presently have robust automated internal systems for accounting and reconciliation may face issues in making appropriate disclosures in GSTR 3B, which may in turn increase departmental interventions.
