SMS/Emails received regarding discrepancy in claiming ITC - GSTR 3B Vs GSTR 2A

Rohit Kumar Singh , Last updated: 03 June 2019
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Update Category: SMS/E-mails regarding the discrepancy in Claiming ITC - GSTR 3B Vs GSTR 2A
Update Source: Notices by Tax Authorities for Mismatch in ITC Claimed
Release No.: TM/GST/036 dated 01st June, 2019

Excess availment/ Mismatch of GST Input Tax Credit (ITC) claimed in GSTR 3B Vs appearing in GSTR 2A.

With almost two years into GST implementation, the Government is putting all efforts to attain two fold agenda of curbing tax evasion by ensuring compliance and to boost up revenue collection.

Recently, many taxpayers across the country have received SMS and emails from tax authorities (GST Jurisdictional office) with regard to excess availment of ITC in GSTR 3B with ITC auto populated in GSTR 2A.

If you have received any such notice or get any such notice in future, you may follow the below suggestions:

Discrepancy in ITC availed in GSTR 3B

Suggestion by TaxMarvel

The Taxpayers who have availed excess ITC in form GSTR-3B (Domestic Purchases – All other ITC of GSTR 3B) from those which got auto populated in GSTR 2A (Filing GSTR-1 by the Suppliers), the Jurisdictional GST Department is issuing notices through SMS and E-mails.

We suggest you to take following actions:

Verify the correctness of the figure sent to you by the Department.
In case of any discrepancy in figures notified to you, please reach out to Department for correcting the same.
In case of discrepancy write to department that you shall ask suppliers to comply.
In case of any discrepancy in ITC availed, ask the Suppliers to immediately file GSTR 1 by including the details of invoices raised on you.
You may design the below SOP to avoid any interest/ penalty for such mismatches :

Periodically reconcile your Purchase Register with GSTR 2A i.e. monthly/quarterly.
Identify the differences and take below action:

Avail any credit of invoices not appearing in PR but filed by Supplier.
Notify Supplier for missing invoices in 2A
Take action on mismatches of tax amount, tax type or invoice No./date.
Also reconcile all Credit/Debit Notes issued by Supplier with those appearing in books.

In case any Supplier is found to be non-compliant, we suggest to have discussion with them to file their returns. If they don’t comply within reasonable time period deduct the tax and interest exposure to cover your prospective losses.