Advisory on newly introduced Form GSTR-2B – (Auto-drafted ITC statement)

GSTR-2B

GSTR-2B was a new static month-wise auto-drafted ITC statement for regular taxpayers introduced on the GST portal. The statement was launched from the tax period August 2020. However no reference to this form was there in CGST Act / CGST Rules,2017.

In order to provide legal sanction to Form GSTR-2B amendment has been made in the CGST Rules, 2017 vide Notification No. 82/2020–Central Tax dated 10-11-2020 wherein interalia Rule 60 of the CGST Rules, 2017 has been substituted. As per sub-rule (7) and (8) of substituted Rule 60, legal backing has been provided to Form GSTR-2B.

For ready reference of our readers the sub-rule (7) and (8) are reproduced below:

(7) An auto-drafted statement containing the details of input tax credit shall be made available to the registered person in FORM GSTR-2B, for every month, electronically through the common portal, and shall consist of –

(i) the details of outward supplies furnished by his supplier, other than a supplier required to
furnish return for every quarter under proviso to sub-section (1) of section 39, in FORM GSTR-1,
between the day immediately after the due date of furnishing of FORM GSTR-1 for the previous
month to the due date of furnishing of FORM GSTR-1 for the month;

(ii) the details of invoices furnished by a non-resident taxable person in FORM GSTR-5 and
details of invoices furnished by an Input Service Distributor in his return in FORM GSTR-6 and
details of outward supplies furnished by his supplier, required to furnish return for every quarter
under proviso to sub-section (1) of section 39, in FORM GSTR-1 or using the IFF, as the case
may be,-
-(a)
for the first month of the quarter, between the day immediately after the due date of furnishing of FORM GSTR-1 for the preceding quarter to the due date of furnishing details using the IFF for the first month of the quarter;
-(b) for the second month of the quarter, between the day immediately after the due date of furnishing details using the IFF for the first month of the quarter to the due date of furnishing details using the IFF for the second month of the quarter;
-(c) for the third month of the quarter, between the day immediately after the due date of furnishing of details using the IFF for the second month of the quarter to the due date of furnishing of FORM GSTR-1 for the quarter;

(iii) the details of the integrated tax paid on the import of goods or goods brought in the domestic
Tariff Area from Special Economic Zone unit or a Special Economic Zone developer on a bill o
entry in the month.

(8) The Statement in FORM GSTR-2B for every month shall be made available to the registered person,-
(i) for the first and second month of a quarter, a day after the due date of furnishing of details of outward supplies for the said month, in the IFF by a registered person required to furnish return for every quarter under proviso to sub-section (1) of section 39, or in FORM GSTR-1 by a registered person, other than those required to furnish return for every quarter under proviso to sub-section (1) of section 39, whichever is later;
(ii) in the third month of the quarter, a day after the due date of furnishing of details of outward supplies for the said month, in FORM GSTR-1 by a registered person required to furnish return for every quarter under proviso to sub-section (1) of section 39.

Further vide Notification No. 82/2020–Central Tax dated 10-11-2020 the format of GSTR-2B has also been inserted in CGST Rules,2017.

Advisory on GSTR-2B

1. a) FORM GSTR-2B is a statement which has been generated on the basis of the information furnished by your suppliers in their respective FORMS GSTR-1,5 and 6. It is a static statement and will be made available once a month. The documents filed by the supplier in any FORMS GSTR-1,5 and 6 would reflect in the next open FORM GSTR-2B of the recipient irrespective of supplier’s date of filing. Taxpayers are advised to refer FORM GSTR-2B for availing credit in FORM GSTR-3B. However, in case for additional details, they may refer to their respective FORM GSTR-2A (which is updated on near real time basis) for more details.

b) Input tax credit shall be indicated to be non-available in the following scenarios: –

i. Invoice or debit note for supply of goods or services or both where the recipient is not entitled to input tax credit as per the provisions of sub-section (4) of Section 16 of CGST Act, 2017.

ii. Invoice or debit note where the Supplier (GSTIN) and place of supply are in the same State while recipient is in another State.

However, there may be other scenarios for which input tax credit may not be available to the taxpayers and the same has not been generated by the system. Taxpayers, should self-assess and reverse such credit in their FORM GSTR-3B.

2. It may be noted that FORM GSTR-2B will consist of all the FORM GSTR-1s, 5s and 6s being filed by your suppliers, generally between the due dates of filing of two consequent GSTR-1 or furnishing of IFFs, based on the filing option (monthly or quarterly) as chosen by the corresponding supplier. The dates for which the relevant data has been extracted is specified in the CGST Rules and is also available under the “View Advisory” tab on the online portal. For example, FORM GSTR-2B for the month of February will consist of all the documents filed by suppliers who choose to file their FORM GSTR-1 monthly from 00:00 hours on 12th February to 23:59 hours on 11th March.

3. It also contains information on imports of goods from the ICEGATE system including data on imports from Special Economic Zones Units/Developers.

4. It may be noted that reverse charge credit on import of services is not part of this statement and will be continued to be entered by taxpayers in Table 4(A)(2) of FORM GSTR-3B.

5. Table 3 captures the summary of ITC available as on the date of generation of FORM GSTR-2B. It is divided into following two parts:

A. Part A captures the summary of credit that may be availed in relevant tables of FORM GSTR-3B.

B. Part B captures the summary of credit that shall be reversed in relevant table of FORM GSTR-3B.

6. Table 4 captures the summary of ITC not available as on the date of generation of FORM GSTR-2B. Credit available in this table shall not be availed as credit in FORM GSTR-3B. However, the liability to pay tax on reverse charge basis and the liability to reverse credit on receipt of credit notes continues for such supplies.

7. Taxpayers are advised to ensure that the data generated in FORM GSTR-2B is reconciled with their own records and books of accounts. Tax payers shall ensure that

a. No credit shall be taken twice for any document under any circumstances.

b. Credit shall be reversed wherever necessary.

c. Tax on reverse charge basis shall be paid.

8. Details of invoices, credit notes, debit notes, ISD invoices, ISD credit and debit notes, bill of entries etc. will also be made available online and through download facility.

9. There may be scenarios where a percentage of the applicable rate of tax rate may be notified by the Government. A separate column will be provided for invoices/documents where such rate is applicable.

10. Table wise instructions:

Table No. and HeadingInstructions
Table 3 Part A
Section I All other ITC – Supplies from
registered persons
other than reverse charge
i. This section consists of the details of supplies (other than those on which tax is to be paid on reverse charge basis), which have been declared and filed by your suppliers in their FORM GSTR-1 and 5.
ii. This table displays only the supplies on which input tax credit is available.
iii. Negative credit, if any may arise due to amendment in B2B– Invoices and B2B – Debit notes. Such credit shall be reversed in Table 4(B)(2) of FORM GSTR-3B.
Table 3 Part A
Section II Inward Supplies
from ISD
i. This section consists of the details of supplies, which have been declared and filed by an input service distributor in their FORM GSTR-6.
ii. This table displays only the supplies on which ITC is available.
iii. Negative credit, if any, may arise due to amendment in ISD Amendments – Invoices. Such credit shall be reversed in table 4(B)(2) of FORM GSTR-3B.
Table 3 Part A
Section III- Inward Supplies
liable for reverse
charge
i. This section consists of the details of supplies on which tax is to be paid on reverse charge basis, which have been declared and filed by your suppliers in their FORM GSTR-1.
ii. This table provides only the supplies on which ITC is available.
iii. These supplies shall be declared in Table 3.1(d) of FORM GSTR-3B for payment of tax. Credit may be availed under Table 4(A)(3) of FORM GSTR-3B on payment of tax.
Table 3 Part A
Section IV-Import of Goods
i. This section provides the details of IGST paid by you on import of goods from overseas and SEZ units / developers on bill of entry and amendment thereof. These details are updated on near real time basis from the ICEGATE system.
ii. This table shall consist of data on the imports made by you (GSTIN) in the month for which FORM GSTR-2B is being generated for.
iii. The ICEGATE reference date is the date from which the recipient is eligible to take input tax credit.
iv. The table also provides if the Bill of entry was amended.
v. Information is provided in the tables based on data received from ICEGATE. Information on certain imports such as courier imports may not be available.
Table 3 Part B
Section I Others
i. This section consists of the details of credit notes received and amendment thereof which have been declared and filed by your suppliers in their FORM GSTR-1 and 5
ii. Such credit shall be reversed under Table 4(B)(2) of FORM GSTR-3B. If this value is negative, then credit may be reclaimed subject to reversal of the same on an earlier instance.
Table 4 Part A
Section I All other ITC -Supplies from
registered persons
other than reverse charge
i. This section consists of the details of supplies (other than those on which tax is to be paid on reverse charge basis), which have been declared and filed by your suppliers in their FORM GSTR-1 and 5.
ii. This table provides only the supplies on which ITC is not available.
iii. This is for information only and such credit shall not be taken in FORM GSTR-3B.
Table 4 Part A
Section II Inward Supplies
from ISD
i. This section consists of the details supplies, which have been declared and filed by an input service distributor in their FORM GSTR-6.
ii. This table provides only the supplies on which ITC is not available.
iii. This is for information only and such credit shall not be taken in FORM GSTR-3B.
Table 4 Part A
Section III Inward Supplies
liable for reverse
charge
i. This section consists of the details of supplies liable for reverse charge, which have been declared and filed by your suppliers in their FORM GSTR-1.
ii. This table provides only the supplies on which ITC is not available.
iii. These supplies shall be declared in Table 3.1(d) of FORM GSTR-3B for payment of tax. However, credit will not be available on such supplies.
Table 4 Part B Section I Othersi. This section consists details the credit notes received and amendment thereof which have been declared and filed by your suppliers in their FORM GSTR-1 and 5
ii. This table provides only the credit notes on which ITC is not available.
iii. Such credit shall be reversed under Table 4(B)(2) of FORM GSTR-3B.

Full forms of abbreviations used in Advisory:

a. ITC – Input tax credit

b. B2B – Business to Business

c. ISD – Input service distributor

d. IMPG – Import of goods

e. IMPGSEZ – Import of goods from SEZ

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