With introduction of GSTR-2B , a question that is blinking in mind of tax payers is that whether they should now for purpose of availing of ITC refer to GSTR-2A or GSTR-2B. We shall briefly try to delve on this issue in this article. Before proceeding lets go through the basics of GSTR-2B and its comparison with GSTR-2A.
1. What is GSTR-2B:
a. GSTR-2B is an auto-drafted ITC statement generated for every registered person (other than composition dealer) based on GSTR-1, 5 (non-resident taxable person), and 6 (input service distributor) filed by supplier.
b. GSTR-2B is a static statement available for each month on the 12th of the succeeding month. E.g.: August 2020 statement available on 12th September 2020.
c. GSTR-2B for a month (M) contains all documents filed by suppliers between the due date of furnishing of GSTR-1 for the previous month (M-1) to the due date of furnishing of GSTR-1 for the current month (M).
E.g. for August 2020, documents filed by suppliers from 00:00 hours on 12.08.2020 to 23:59 hours on 11.09.2020 will be included in GSTR-2B generated on 12.09.2020. If there is delay in filing of such GSTR-1 and suppose it is filed on 12.09.2020, then such amounts will be captured in the GSTR-2B generated for month of September, on 12.10.2020.
d. Instances where the return due date is later than the date of generation of GSTR 2B, it is advised to avail ITC on a self-assessment basis.
e. The documents would reflect in the next open GSTR-2B of the recipient irrespective of the date of the document. E.g. INV-1 dated 15.08.2020 uploaded in September 2020 return filed on 11.10.2020, it would be reflected in GSTR-2B of September 2020 generated on 12.10.2020 and not in GSTR-2B of August, 2020.
2. Comparison of GSTR 2A and GSTR 2B:
| Comparison points | GSTR 2B | GSTR 2A |
| Nature | Static – Details uploaded by vendors after the cut-off date considered in the subsequent period. | Dynamic, as it changes from day to day, as and when the supplier uploads the documents. |
| Frequency | Monthly | Monthly |
| Source of information | GSTR 1, GSTR 5, GSTR 6, ICEGATE system – Would not provide details of TDS & TCS deductions. | GSTR 1, GSTR 5, GSTR 6, GSTR 7, GSTR 8, ICEGATE system – BoE details recently updated. |
| Usefullness | Very useful in ITC reconciliations (especially Rule 36(4)), and to identify compliant/non-compliant vendors. | Very difficult to ensure all GSTR 2A credits are considered as vendors may delay filing returns. |
| Features | Online portal has various features (discussed later in the article) | Limited features. |
Apart from GSTR-2B also indicates the ITC not available in respect of following cases, which is not depicted by GSTR-2A.
i. Recipient not entitled to take the credit based on a time limit in Section 16(4) of the CGST Act.
ii. Invoice or debit note where the Supplier (GSTIN) and place of supply are in the same State while the recipient is in another State. (Ex: accommodation services).
However other ineligible ITC like , ITC blocked u/s 17(5) of the CGST Act, 2017 will not be captured in GSTR-2B and thus taxpayer needs to be vigilant to identify other ineligible credits and not to avail them.
3. Input Tax Credit (ITC): Should taxpayer use GSTR-2B or GSTR-2A now:
Unlike GSTR-2A which may change over a period of time on account of late GSTR-1 filing or amendments, GSTR-2B will remain , the same , since it is generated on the basis of GSTR-1 filed between two specific dates as explained in above paras.
Therefore the taxpayers are advised to refer GSTR-2B for availing credit in GSTR-3B. However in case for additional details , they may refer to their respective GSTR-2A (which is uploaded on near real time basis) for more details.
Further apart from the eligible amount as per GSTR-2B including additional details in GSTR-2A the tax payer can avail further amount upto 10% of such eligible ITC or the invoices not appearing in GSTR-2A / 2-B whichever is less in accordance with Rule 36(4) of the CGST Rules, 2017.
4. Is there any statutory requirement to reconcile ITC under GSTR-2A and GSTR-2B?
Further the taxpayer should note here that there is no statutory requirement to reconcile GSTR-2A and GSTR-2B. However tax payer at time of filing GSTR-3B may check GSTR-2A to identify any further invoices not appearing in GSTR-2B and avail its ITC. However he should ensure not to avail credit such ITC again in next month on basis of GSTR-2B of next month.
It may further be noted here that GSTR-2B as on date has no legal backing. It is expected that Govt would include the same soon in the statute books of GST to avoid legal issues in this regard.
5. Reconciliation of ITC with Matching offline tool:
Further the taxpayer should reconcile its GSTR-2B with purchase register for which Matching Offline Tool has been made available by GSTN. This is an offline tool to view Form GSTR 2B and match the auto drafted details in Form GSTR-2B with the purchase register. The match results are used to create the matching report in offline mode. For details in regard to matching tool click here
6. Is availing ITC on self assessment basis possible after GSTR-2B:
There may be instances where the date of filing of GSTR-5 (Non-Resident taxable person) and GSTR-6 (Input Service Distributor) may be later than the date of generation of GSTR-2B. Under such circumstances, taxpayers are advised to avail input tax credit on self-assessment basis. However, when such document gets filed and reflected in their next GSTR-2B, taxpayers shall not avail such input tax credit.
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Frah Saeed is a law graduate specializing in the core field of indirect taxes and is the Co-founder of taxwallah.com. She has authored many publications on GST and is into full-time consultancy on GST to big corporates. She as a part of taxwallah.com heads a team comprising of Chartered Accountants and Advocates and plays a key role in our mission to disseminate GST knowledge to all.
