Auditor's recommendation under GSTR 9C


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This discussion addresses a common issue in GSTR 9C where Input Tax Credit (ITC) is claimed in audited accounts and GSTR-3B but not reflected in GSTR-2A. The core question is how an auditor should recommend handling this discrepancy. Experts suggest that while the ITC might be validly held, it's crucial to acknowledge the contravention of Rule 36(4) in the audit report if it wasn't available in GSTR-2A at the time of annual filing.

28 December 2020 Dear Experts,

There is ITC of around 2 lakh which is claimed in audited accounts as well as in annual returns
via GSTR 3B due availability of GST invoice in hand.
Table IV of form 9C therefore did not show the difference of said ITC as both in accounts and annual return, this ITC has been claimed.
However, in GSTR 2A this ITC of 2 Lac is not available. GSTR 9 shows the difference of 2 lac being ITC claimed in annual return but not available in GSTR 2A

My question is what would be auditor recommendation in this case ? shall auditor recommend to pay in GSTR 9C amount not available in GSTR 2A ? or can we claim this valid ITC even if not available under 2A

28 December 2020 As per my view we can not claim any ITC at the time of Annual Fillings if these are not uploaded by the Suppliers.

28 December 2020 You should qualify in report that the ITC is claimed in contravention of rule 36(4).


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