Handling GSTR-2B reconciliation

https://www.caclubindia.com/forum/a-word-of-caution-the-sudden-rise-of-suspicious-quot-client-document-collection-quot-pitches-615111.asp

The question of who owns the ITC mismatch is something most CA firms have had to formally address in their engagement terms.

Practically speaking, the mismatch falls into two categories:

1. Supplier filing error: The supplier has not filed GSTR-1 or filed it with wrong invoice details. The CA firm can only notify the client to follow up with the supplier. If GSTR-2B does not correct itself before the return deadline, ITC either waits or gets claimed subject to reversal risk.

2. Client accounting mismatch: The purchase register differs from GSTR-2B because the client team missed invoices, duplicated entries, or coded them incorrectly. If the CA is NOT doing the bookkeeping, this is the client responsibility to reconcile. The CA can identify the mismatch but cannot correct source data they do not own.

The IMS (Invoice Management System) from October 2025 makes the ownership question sharper. ITC is no longer auto-populated in GSTR-3B. The client (or CA on their behalf) must actively accept or reject invoices in IMS before filing. Whoever is managing IMS actions is effectively owning the reconciliation.

Most CA firms are now adding a clause to engagement letters: either the client provides a reconciled purchase register before the deadline, or the CA files on available GSTR-2B data with a caveat note. The liability for differences stays with the client unless the CA also manages bookkeeping.

For firms managing both bookkeeping and GST returns, this [GSTR-9C reconciliation guide](https://taxgarden.in/blog/gstr-9c-reconciliation-statement-guide-fy-2025-26) covers the annual reconciliation approach that resolves these mismatches at year-end.