Under GST, the responsibility of making sure that a supplier correctly reports B2B details in his GSTR-1 and therefore, the process of GSTR-2A reconciliation with purchase records lies on the recipient.
BUT, the GSTR-2A report available on the GST portal includes amended as well as it's original B2B details. There is no indication against the original B2B record mentioning whether the same is amended and if it is re-assigned to a different recipient.
(GSTR-2A is the only source of information available to a recipient to ascertain his ITC as per government records)
Let's say, FOR EXAMPLE, a supplier mistakenly amends the recipient GSTIN in his B2B sales invoice. Because the amended invoice is now assigned to a different recipient, the amended invoice will NOT show up anywhere in the original recipient's GSTR-2A. Hence, there is no way for the original recipient to find out from his GSTR-2A data that the supplier has re-assigned his purchase to a third party, and therefore reducing his rightful ITC. UNFORTUNATELY, an amended invoice can NOT be amended again, which makes it very difficult for the original (correct) recipient to re-claim ITC on that invoice.
Even if somehow, the recipient or supplier finds out the error in a timely manner and issues a credit note to nullify the amended invoice (within the stipulated time as per GST law), the supplier can only issue new invoice to the original recipient in current date (whereas the recipient declared ITC against the same in a prior period GSTR-3B, which technically makes his case as reporting excess ITC), which unnecessarily attracts interest @ 24% p.a. on the ITC amount -from the period of original sales -to the period in which the new invoice is issued.
HOWEVER, it is pertinent that finding the mistake after the stipulated time period for issuing a credit note is over (assuming GSTR-1 is filed for that period), nothing can be done thereafter.
There should be a mechanism in place to protect such recipient's rightful ITC, and promptly reporting to them all invoices and credit/debit notes amended by supplier wherein their GSTIN was removed.
I am NOT sure if this is effectively handled in the new GST returns to be implemented shortly.
CAclubindia
