Gst on Guest house 5% without ITC

 

 

 

 

Hi Everyone,

 

Looking for guidance/opinions from fellow practitioners regarding a specific GSTR-3B handling scenario for a client providing guest house accommodation services taxable at **5% GST without ITC** (under Notification No. 11/2017-Central Tax (Rate)).

 

### **Context & Past Action Taken:**

 

1. **Initial Mistake:** In Month 1 (first return), the entire inward ITC auto-populated in GSTR-3B Table 4(A)(5) from GSTR-2B was availed without manual reversal in Table 4(B)(1).

2. **Current Ledger Status:** The wrongly availed ITC was **never utilized** to set off any tax liability; the Electronic Credit Ledger balance remained intact.

3. **Rectification:** To clean up the ledger, we filed **Form GST DRC-03** under *Voluntary Payment (Wrong ITC Availed)* on the same day and debited the amount directly from the **Electronic Credit Ledger**.

 

---

 

### **Queries for the Forum:**

 

1. **DRC-03 vs GSTR-3B Table 4(B)(1) Adjustment:**

Since the ITC was unutilized, is DRC-03 (Paid via Credit Ledger) the cleanest approach, or would you recommend making a cumulative reversal in Table 4(B)(1) of the subsequent month’s GSTR-3B despite portal warnings of negative net ITC?

2. **Standard SOP for Future Filings:**

As per CBIC Circular No. 170/02/2022-GST:

* Is accepting vendor invoices in IMS and letting 100% of GSTR-2B auto-populate into Table 4(A)(5), followed by an exact **100% permanent reversal in Table 4(B)(1)**, the standard monthly workflow you follow for 5% non-ITC clients?

 

 

3. **Risk of Automated Scrutiny (ASMT-10):**

Has anyone faced automated scrutiny notices for reversing 100% of GSTR-2B credit under Table 4(B)(1) every month, and does presenting Circular 170 satisfy the GST officer in practice?

 

Looking forward to your expert insights. Thanks in advance!

Replies (3)
Quick Summary
This discussion seeks guidance on rectifying an accidental ITC claim for a client providing guest house services taxed at 5% GST without input tax credit. The initial mistake involved auto-populating inward ITC in GSTR-3B without reversal. Although the ITC was never used, the practitioner used Form GST DRC-03 to debit the credit ledger. The user is asking for confirmation on this method versus a GSTR-3B reversal, and seeking standard operating procedures for future filings, particularly regarding CBIC Circular 170/02/2022-GST, and the potential risks of automated scrutiny notices for monthly 100% ITC reversals.

  • Month 1 Error: DRC-03 debited against the Electronic Credit Ledger was the correct remedy. Because the credit was never utilized, no interest is payable under Section 50(3).

  • SOP for Future Months: Accept invoices in IMS $\rightarrow$ Allow GSTR-2B to auto-populate Table 4(A)(5) $\rightarrow$ Manually record a 100% permanent reversal in Table 4(B)(1) $\rightarrow$ Net ITC in Table 4(C) becomes ₹0.

  • Scrutiny Defense: This workflow complies with CBIC Circular 170/02/2022-GST and satisfies GST audit and scrutiny requirements

Okay, Actually I also have the same view but want experienced view on it. Thankyou.

A guest house at 5% without ITC and the whole 2B flowing into 4(A)(5) is a very common first-month slip.

The main point on your first question: interest under Section 50(3) applies to wrongly availed ITC only when it is also UTILISED. Since the credit sat unused in the ledger, you are mostly looking at a correction, not an interest case. So the route matters less than having a clean record:
- Reverse it in GSTR-3B of the earliest open month, and keep a note of the month and amount.
- If you have already paid through DRC-03 out of the credit ledger, keep the ARN and ledger entry with the file so the two entries can be tied together if a notice comes.
- Do not do both. Reversing in 3B and also paying DRC-03 would double count.

On the monthly workflow: if the client can never take ITC on the 5% supply, reversing 100% every month is noise that invites questions. Better to fix it at the source: check what the entry actually allows (some inputs and input services may be eligible under the notification conditions) and claim only that portion. Then the 3B shows a small, explainable reversal instead of a full one.

On ASMT-10: a full reversal is not a mismatch that the department flags on its own. Scrutiny usually comes from 2B vs 3B differences, so keep a simple working sheet showing 2B ITC, eligible ITC, reversed ITC and the reason.

More on the correction and interest side is in this [DRC-03 voluntary payment guide](https://taxgarden.in/blog/gst-drc-03-voluntary-payment-guide-india-2026).

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