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Reporting of reclaimable reversal

09 February 2024

The time limit of reporting of reclaimable reversal of ITC expired on 31/01/2024. Is any extention in the same expected? Is the ITC lapsed if the tax payer could not report it and ITC is huge?

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23 Replies

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 09 February 2024

It's lapsed if not reported. Also check the ITC reclaim ledger

Mohan Kale (342 Points)
Replied 10 February 2024

Any extention expected?

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 10 February 2024

No as it was already extended earlier

Mohan Kale (342 Points)
Replied 10 February 2024

Thank you.

1 Like

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 10 February 2024

Welcome

CA Altamush Zafar (GST Consultant) (15907 Points)
Replied 10 February 2024

There is no legal backing of this reporting. You can take ITC if ITC was taken in time and reversed or again taken within time. Although reporting would reduce litigation.

Mohan Kale (342 Points)
Replied 11 February 2024

Are you sure about its legal invalidity?

CA Altamush Zafar (GST Consultant) (15907 Points)
Replied 11 February 2024

There is no section or rule where the opening balance is to be reported.

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 11 February 2024

The GSTN has issued Advisory No. 619 dated December 29, 2023 regarding the due date extension for reporting opening balance for ITC reversal which states that :

In order to facilitate the taxpayers in correct and accurate reporting of ITC reversal and reclaim thereof and to avoid clerical mistakes, a new ledger namely Electronic Credit and Re-claimed Statement was introduced on the GST portal. This statement was made available to help the taxpayers in tracking their ITC that has been reversed in Table 4B(2) and thereafter re-claimed in Table 4D(1) and 4A(5).

Now to facilitate taxpayers further, opportunity to declare opening balance for ITC reversal in the statement has been extended till January 31, 2024.

CA Altamush Zafar (GST Consultant) (15907 Points)
Replied 11 February 2024

GSTN is no authority and the word advisory speaks for itself that it is not mandatory.

However to avoid litigation one might fill the opening balances

But even though it is not filled then also ITC cannot be denied if taken in time and reclaimed after reversal.

Mohan Kale (342 Points)
Replied 11 February 2024

Exactly my point. Which is what I was anxious about and wanted to know whether based on this reporting is there going to be any effect in re-availing, and utilising the ITC earlier reversed? Or if there would be any default generated? Or any notice likely to be issued etc...

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 12 February 2024

You can avail but later on you have to clarify the department for the reason of claiming excess ITC as scrutiny notice will definately issued

You must have the details of ITC which is reversed earlier and thereafter you can claim such ITC. Reversal must be made in Other ITC reversal column i.e Table 4B(2).

1 Like

CA Altamush Zafar (GST Consultant) (15907 Points)
Replied 12 February 2024

@ CA Rashmi Gandhi
it took you just three days to go from saying that 'ITC will lapse' to 'you can take ITC' and then liking your own reply yourself.
A prime example for the people to know how authentic you and your opinion are.

CA Rashmi Gandhi (Chartered Accountant) (86225 Points)
Replied 12 February 2024

I agreed on my first point now also but if the tax payer is agreed to go into litigation then he can claim.

But I personally suggest not to indulge in litigation for a small amount.