Electronic Credit Reversal and Reclaimed statement : This statement relates to the notified changes made in the GSTR 3B returns to enable taxpayers in reporting correct information regarding ITC availed, ITC reversal, ITC re-claimed and ineligible ITC. Pertains to which notification: – Vide Notification No. 14/2022 – Central Tax dated 05th July, 2022 (read with circular 170/02/2022-GST, Dated 6th July,2022).
As per the mentioned notification the reclaimable ITC earlier reversed in Table4(B)(2) may be subsequently claimed in Table 4(A)5 on fulfilment of necessary conditions. Such reclaimed ITC in Table 4(A)5 also needs to be explicitly reported in Table 4D(1).
Key features of Electronic Credit Reversal and Reclaimed Statement
1. Monthly Filers shall Report opening balance considering the ITC reversal made until the return period of July 2023.
2. Quarterly Filers shall report the opening balance up to Q1 of the financial year 2023-24, considering the ITC reversal until the April-June 2023 return period.
3. Taxpayers have the opportunity to declare their opening balance for ITC reversal by 30th November 2023.
4. After 30th November, until 31st December 2023, only amendments will be permitted. The option for fresh reporting will not be available after this date.
5. The Taxpayers are only permitted to manually enter the opening balance of ITC Reversal pending to be yet reclaimed
For reporting, Login the GST Portal and visit tab Services > Ledger-Electronic Credit Reversal and Re-claimed Statement > Report ITC Reversal Opening Balance.
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FAQs on Reporting ITC Opening Balance in Electronic Credit and Reclaimed Statement
Question: If we have reversed amount of Rs 20,000 in GSTR 3B of Oct 2023 and we will reclaim this in Nov 2023. We have no other amount to reclaim till now. Whether it is required to mention in table “Declaration of Opening Balance of Accumulated ITC Reversal pending for re-claim”?
Answer: Yes, it is required to mention if we have an Accumulated ITC that is reversed in Table4(B)(2) that is eligible for re-claim but has not yet been re-claimed till date under this functionality. Taxpayers may report their opening balance until 30th November 2023. After that it will be assumed that the taxpayer has no ITC Reversal Balance to report. Though 3 amendment opportunities are available till 31st December 2023.
That ITC may be subsequently claimed in Table 4(A)(5). Such reclaimed ITC also needs to be explicitly reported in Table 4D(1) of GSTR-3B.
Proper working Should be maintained for reporting under this functionality as once opening cumulative ITC Reversal balance pending for reclaiming is reported then the amounts mentioned in Table 4B(2) and Table 4D (1) in subsequent GSTR-3B will be auto populated in the Electronic Credit and Re-claimed Statement and closing balance will be automatically calculated. After that, in the following GSTR 3B Returns ITC Reclaim reporting under Table 4D(2) cannot exceed the closing balance as reflected in the Electronic Credit and Re-claimed Statement.
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Question: Can it be amended and last date?
Answer: If any mistakes or inaccuracies occur while reporting the opening Cumulative ITC Reversal balance then opportunity of amendment shall be provided upto maximum of 3 times. The last date to amend the opening balance entered in Electronic Credit and Re-claimed Statement is 31st December 2023. After 31st December 2023 no amendments shall be allowed After 31st December 2023,the balance will be locked and it shall be sent to jurisdictional officers for review
Question: Whether the taxpayers will be able to file the return, if the amount of reclaimed ITC in Table 4D(1) of GSTR 3B exceeds the balance reflecting in the Electronic credit reversal and reclaimed statement?
Answer: If the amount of reclaimed ITC exceeds the balance reflecting in the statement then the system will trigger a warning message to facilitate the accurate reporting but the taxpayers can still proceed with the filing. However, there may be possibility that department may issue a notice in Form DRC-01C as per the Notification No. 38/2023 dated 04th August, 2023 to explain the difference between the eligible input tax credit reflecting in auto-generated statement i.e. GSTR 2B and that availed in the return.
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