GST ITC DURING SUSPENSION

Need expert opinion on a GST ITC issue.

Client GST registration was under suspension during a certain period due to Non-filing of Returns. Supplier has correctly filed GSTR-1 and invoices are reflecting in GSTR-2A, but the ITC is not appearing in GSTR-2B for that period.

Queries:

  1. Can such ITC still be availed manually in GSTR-3B of subsequent period based on 2A and valid invoices/documents of the previous month?

  2. Has anyone faced similar issue during suspension/cancellation period?

  3. Will department likely raise notice due to mismatch with 2B?

  4. Any specific circular/rule/portal mechanism available for such cases?

Registration has now been restored/active.

Would appreciate practical experiences and legal views.

Replies (2)
Quick Summary
GST ITC may not appear in GSTR-2B during registration suspension even if invoices reflect in GSTR-2A. After restoration, taxpayers may manually claim eligible ITC in GSTR-3B with proper invoices and reconciliation, though mismatch notices from the department remain possible.

  • Claiming ITC: You can claim it manually in GSTR-3B now that the registration is active.

  • Basis: Use GSTR-2A and physical invoices since GSTR-2B was not generated.

  • Risks: Expect an automated mismatch notice, but it is defensible with proper reconciliation and the revocation order.

1) What is the certain period the registration was under suspension?. 

2) Invoices pertains to which month and year? . 

3) Supplier has to fie not only   GSTR1 but GSTR3B as well , so has he filled?. 

 

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