Navigating the Discrepancies Between GSTR-9 Table 8A and 8C in Annual Returns

The GSTR-9 annual return for Financial Year (FY) 2023-24 is approaching its deadline of December 31, 2024. Many taxpayers are encountering challenges due to disparities between Table 8A and Table 8C of this annual return. Table 8, which focuses on other input tax credit (ITC) related information, is crucial for detailing the ITC available versus the ITC claimed for the entire financial year. Recognizing these issues, the GST Network (GSTN) released an important advisory on December 9, 2024, to clarify the reasons behind these differences. This document thoroughly examines the ITC specifics for FY 2023-24 as presented in these tables, their underlying data sources, and common scenarios for ITC claim reporting, aiming to promote accurate compliance.

Understanding Tables 6 and 7 of GSTR-9

Table 6 of GSTR-9 outlines the input tax credit (ITC) availed during the financial year, such as FY 2023-24, as recorded in GSTR-3B. Taxpayers are required to report ITC values separately for CGST, SGST, IGST, and cess. A detailed breakdown of ITC on inputs, input services, and capital goods is necessary, though input services can be grouped with inputs.

Transaction types covered under this table encompass:

• Imports of goods and services
• Goods and services received from SEZ
• Purchases from both GST-registered and unregistered persons but liable to reverse charge
• ITC from Input Service Distributor (ISD)
• ITC reclaimed after reversals
• Transitional ITC (applicable for FY 2017-18)

Conversely, Table 7 of GSTR-9 is dedicated to reporting input tax credit (ITC) that has been reversed or deemed ineligible for the financial year, such as FY 2023-24. This information can be derived from Table 4(B) of GSTR-3B (ITC reversed) and Form ITC-03 (Intimation of ITC reversal). If ineligible ITC amounts, initially reported in Table 4D of GSTR-3B, were previously part of Table 4A of GSTR-3B (ITC available), they should then be reflected in Table 7E of GSTR-9.

The ineligibility or reversals can arise from applying:

• CGST Rules 37 (reversal due to non-payment of purchase invoice in 180 days)
• CGST Rule 39 (reversals pertaining to ISD ITC)
• CGST Rule 42 (reversal of common credit on inputs and input services attributable to exempt or non-business supplies/purposes)
• CGST Rule 43 (reversal of common credit on capital goods attributable to exempt or non-business supplies/purposes)
• CGST Section 17(5) (ineligible ITC)
• It could also be due to the reversal of transitional credits previously claimed, applicable for FY 2017-18.

Decoding Table 8A of GSTR-9

Table 8A of GSTR-9 presents the total input tax credit (ITC) available for a financial year, as determined by the government, drawing data from Tables 3 and 5 of GSTR-2A or Table 3(I) of GSTR-2B, depending on the specific year. This section is automatically populated by the system, precluding manual edits. The ITC data in GSTR-2A/2B originates from invoices and debit notes uploaded by vendors in their GSTR-1/GSTR-1A filings. Table 8 facilitates a comparison between the ITC claimed, reversed, or deemed ineligible and the total ITC reflected in GSTR-2A/2B. Historically, until FY 2022-23, GSTR-2A (a dynamic auto-drafted ITC statement) served as the reference. However, starting from FY 2023-24, Table 8A of GSTR-9 automatically populates its details from GSTR-2B (a static auto-drafted ITC statement).

Details of ITC available include:

• On all inward supplies other than exceptions
• On services received from SEZs
• On supplies received from e-commerce operators

Details of ITC available exclude:

• On imports
• On inward supplies liable to reverse charge

Guidelines for Reporting in GSTR-9 Table 8C

Table 8C of GSTR-9 requires taxpayers to report ITC details for inward supplies or purchases pertaining to the financial year for which the GSTR-9 is being filed, but where the ITC was actually claimed in the subsequent financial year, up to the permissible deadline under CGST Section 16(4). For instance, if an ITC of Rs. 1,800 related to a purchase invoice dated July 8, 2023, was claimed in the GSTR-3B filed in October 2024, this ITC should be reflected in Table 8C. However, if the same Rs. 1,800 ITC was claimed in the GSTR-3B of November 2024, it would fall outside the deadline stipulated by CGST Section 16(4) and thus not be included in Table 8C. Similarly, if such ITC remained unclaimed, it would not appear in Table 8C but rather in Tables 8E/8F of GSTR-9. It's important to note that delayed or unclaimed ITC would be part of Table 8D, which represents the difference between ITC available in GSTR-2B and ITC not claimed in GSTR-3B by the Section 16(4) deadline. Therefore, if Table 8D is a positive value, then Table 8E + Table 8F will equal Table 8D.

Details of the ITC claimed in this table include:

• On all inward supplies other than the below exclusions
• On services received from SEZs

Details of ITC available exclude imports and inward supplies liable to reverse charge.

Key GSTR-9 Notifications Issued in 2024

An advisory issued on December 9, 2024, brought attention to two significant notifications relevant to Financial Year 2023-24.

Notification No 12/2024 Central Tax dated 10th July 2024

This notification introduced several amendments to the GSTR-9 tables as follows:

• To cover the relevant financial year 2023-24 across the form.
• In Tables 4G1 and 5C1 of GSTR-9, e-commerce operators must report the tax on supplies on which they pay tax under CGST Section 9(5), along with the amendments.
• In Table 5F of GSTR-9, report non-GST supply separately. You can either separately report supplies as exempted and nil-rated supplies or report consolidated information for these two heads as exempted.
• For FY 2023-24 onwards, for Table 8A of the GSTR-9, the government auto-fills the total ITC available for purchases (other than imports and inwards supplies liable to reverse charge but includes services received from SEZs) as per Table 3(I) of GSTR-2B.
• In Tables 10, 11, 12 and 13 of GSTR-9, report transactions of the FY 2023-24 but tax paid/ITC claimed in GSTR-3B of April 2024 to October 2024 filed up to 30th November 2024. For earlier years, the return periods were never specified.

Notification No.20/2024-Central Tax Dated 8th October 2024

Table 8A for FY 2023-24 GSTR-9 is as follows:

Earlier, the Table 8A was as follows:

Scenarios Explaining Differences Between GSTR-9 Table 8A and 8C for FY 2023-24

For Financial Year 2023-24, Tables 8A and 8C of GSTR-9 present particular complexities for taxpayers, primarily due to the shift in the source data for Table 8A from GSTR-2A to GSTR-2B. This transition can lead to data overlaps, where ITC available in GSTR-2A for FY 2022-23 might also appear auto-populated in GSTR-2B for FY 2023-24. The GSTN advisory, issued on December 9, 2024, specifically addresses five key issues concerning GSTR-9 for FY 2023-24, detailing how these situations should be managed within the annual returns. The following examples provide further clarity.

2. Suppose you have an ITC of Rs.1,800 for the invoice dated 8th July 2023. Your vendor reported it in their GSTR-1 of March 2024 and filed it by 10th April 2024. ITC of Rs.1,800 will flow into Table 8A of GSTR-9 of FY 2023-24. The purchase invoice belongs to FY 23-24, and ITC was claimed in FY 23-24. Due to payment not being made to your vendor within 180 days, ITC was reversed in FY 23-24 in line with the CGST Section 16(2). After paying the vendor, this ITC will be reclaimed in the next FY 2024-25.|Report this reclaimed ITC in Table 6H of GSTR-9 for FY 24-25, not in Tables 8C and 13 of GSTR 9 for FY 2023-24. Similar reporting applies for the ITC reclaimed as per CGST Rule 37A (vendor fails to deposit taxes in their GSTR-3B)|1. Suppose you claim an ITC of Rs.1,80,000 for the invoice dated 8th April 2023 in GSTR-3B of April 2023. Since this invoice was not paid within 180 days, this ITC was reversed in GSTR-3B of September 2023. The invoice was paid in full on 12th June 2024 and this ITC was reclaimed via GSTR-3B of June 2024. In such case, report Rs.1,80,000 in Table 6H of GSTR-9 of FY 2024-25. Such ITC must not be included in Table 8C or 13 of GSTR-9 of FY 2023-24.
3. Suppose, in the same example above, this invoice was paid in full on 12th March 2024, and this ITC was reclaimed via GSTR-3B of March 2024. In such case, report Rs.1,80,000 in Table 6H of GSTR-9 of FY 2023-24. The purchase invoice belongs to FY 2023-24, but you did not receive the goods in the same financial year. Hence, as per the CGST Circular 170, ITC is claimed in Table 4A5 of GSTR-3B and reversed in Table 4B2. Such ITC is reclaimed in the next FY 2024-25 till the deadline given u/s 16(4) of the CGST Act.|Report such reclaimed ITC in Table 8C and Table 13 as this is the ITC of FY 2023-24.|Suppose you claim an ITC of Rs.1,80,000 for the invoice dated 8th March 2024 in GSTR-3B of March 2024. Since the goods were only received in June 2024, this ITC was claimed and reversed in GSTR-3B of March 2024. In such case, report Rs.1,80,000 in Tables 8C and 13 of GSTR-9 of FY 2023-24. Suppose the purchase invoice belongs to FY 2022-23, appearing in Table 8A of GSTR-9 of FY 23-24, as the vendor would have reported the same in GSTR-1 after the due date of filing of GSTR-1 for March 2023.|This is the ITC of the previous year (FY 2022-23), which was auto-populated in Table 8A of GSTR-9 for FY 2022-23. So, this value need not be reported in Tables 8C and 13 of GSTR-9 for FY 2023-24. It has been clarified that Tables 4, 5, 6, and 7 should have the details of the current FY only.|Suppose you have an ITC of Rs.1,800 for the invoice dated 8th July 2022. This ITC value would already be auto-populated in Table 8A of GSTR-9 for FY 2022-23 even if the vendor reported it in FY 2023-24. You must not report this in Table 8C/13 of GSTR-9 for FY 2023-24. A purchase invoice belonging to FY 2023-24 is claimed, reversed and reclaimed in the same year.|A CBIC press release dated 3rd July 2019 clarifies that values in Table 6H is exclusive of Table 6B of GSTR-9. Hence, such ITC can be reported in one of the rows only. Since the ITC claim and reclaim are reported only in one row, you cannot reverse under table 7 of GSTR–9 of FY 23-24.|Suppose you have an ITC claims of Rs.1,800 for the invoice dated 8th July 2023, reversed on 10th August 2023 and reclaimed on 23rd February 2024. Report this ITC value in either Table 6B/6H of GSTR-9 for FY 2023-24. Do not report it in Table 7.

Performing comprehensive input tax credit (ITC) reconciliations throughout the year is crucial for ensuring precise and thorough reporting in GSTR-9. Given that the annual return serves as a primary reference for tax authorities initiating potential scrutinies, any discrepancies in ITC reporting must be resolved before the GSTR-9 filing deadline.