DRAFT REPLY FOR GST ITC IN

GSTR-3B V/S GSTR-2A

Authored By Published By
CA. Rajender Arora Team GSTCORNOR®

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 <<Date>>
<<Details of the Authority >>

<<Complete address of the Authority>>

Subject: Reply to notice for intimating discrepancies in the return after scrutiny as per Section 61 of the
CGST Act, in relation of ITC availed in GSTR-3B vis a vis ITC reflecting in GSTR-2A.

Ref: <<Details of the client along with Notice no. and date>>

GSTIN: <<<…………>>>

Period: <<<…………>>>

Dear Sir,

The company is in receipt of notice dated ……………. issued by your good office seeking clarification for
the alleged discrepancies in ITC availed as per GSTR-3B and as per Form GSTR-2A for the subjected period
tabulated as under: (Copy of notice is attached herewith as Annexure – 1).

Particulars Total - GST

A) Total ITC as per GSTR-3B ×××××
B) Total ITC as per GSTR-2A ×××××
C) Difference (A-B) ×××××

Our Submission

In this regard, the Company has prepared the reconciliation for the subjected period between ITC taken in
the Form GSTR-3B and ITC shown in GSTR-2A. At the outset, the Company would like to submit that the
amount of ITC shown in the Form GSTR-2A has been updated from Rs. ……………… to Rs. …………. as
on <<date of preparation of reconciliation>>

{This point can be stated when there is difference between the ITC as per GSTR-2A as stated in notice and
ITC in GSTR-2A as reflected as on date of preparing the said reconciliation}

The Company has prepared the reconciliation between the ITC taken as per Form GSTR-3B of ……….. and
ITC reflecting in the Form GSTR-2A referred above of ……………

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The reconciliation statement is prepared as under:

Particulars IGST CGST SGST Total

ITC as per GSTR-3B (Other than ITC availed on RCM)
ITC already reversed in GSTR-3B of September 2*2*.
Excess ITC availed (due to clerical mistake)
Invoices not reflecting in GSTR-2A but ITC availed in GSTR-3B
Claimed under different head
Any other reason (if applicable)
Net effective ITC as per GSTR-3B (A)

ITC as per GSTR-2A:

Total ITC reflecting for B2B invoices
B2BA related to FY …….
ITC reflecting in GSTR-2A but not related to the Company.
ITC excess in 2A vis-à-vis 3B
Net effective ITC as per GSTR-2A for the FY 2019-20 (B)
('C) Net Difference (A-B)

The point wise details are mentioned hereunder:

1. ITC already reversed in GSTR-3B of September 2*2*:

The amount of Rs. …………is related to various parties from which the Company has made purchases and
availed the legitimate credit as per law. Moreover, the Company has paid the due amount, but the parties
has not either show the invoices or may be due to any other reason, these invoices are not reflecting in
GSTR-2A of the Company. Therefore, the Company has already reversed the credit of IGST to the tune of
Rs. ………... The said details along with the copy of GSTR-3B for the tax period September 2*2* has been
enclosed herewith as Annexure – 2. Hence the ITC of said amount is deducted from the ITC taken in GSTR-
3B of ……………for the subjected period for the purpose of reconciliation.

2. Excess ITC availed (due to clerical mistake) of Rs. ………:

Due to certain clerical mistakes at time of filing Form GSTR-3B for the tax period ………., the Company has
availed the excess ITC of Rs. ……… of IGST, CGST and SGST each. The details are attached hereunder as
Annexure – 3.

3. Invoices not reflecting in GSTR-2A but ITC availed in GSTR-3B of Rs. ………..:

The Company while reconciling the ITC as per Form GSTR-2A vis a vis ITC availed in GSTR-3B found that
there are various parties whose invoices are not shown in GSTR-2A of the Company even as on date but
the Company has availed the ITC to the tune of Rs…………... The Company has made payments to these
parties as per agreed terms and the Company now agreed to reverse ITC on these invoices, due to non –
reflection of said invoices in GSTR-2A.

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4. ITC Claimed under different head of …………

The Company has purchased ……..<<type of goods>>> from a vendor named <<Details of vendor>>
having GSTIN: …………….. The said vendor has billed to the Company mentioning IGST of Rs. ……..
whereas the amount shown by the vendor in GSTR-1 and accordingly reflecting in GSTR-2A of the
Company in CGST and SGST only, to the tune of Rs. ……. each. Hence, the Company is reversing the IGST
of Rs. ….. from the ITC taken in GSTR-3B of Rs. ………… for the subjected period for the purpose of
reconciliation. Furthermore, on the contrary, the Company is not claiming the ITC of CGST Rs. …….. and
SGST of Rs. ……. as provided in the CGST Act, 2017.

5. ITC reflecting in GSTR-2A but not related to the Company of Rs. ………

The ITC of Rs. ………. has been reflecting in GSTR-2A of the Company for the subjected period, but the
same has not considered and deducted by the Company from the ITC as per GSTR-2A of Rs………. Hence
the amount of Rs. …… is deducted from the ITC reflecting in GSTR-2A of Rs. ………

6. ITC excess in GSTR-2A vis-à-vis GSTR-3B

The Company has identified that the excess ITC is reflecting in GSTR-2A of Rs. ……. CGST and SGST each
as compared to GSTR-3B. The Company has availed the legitimate ITC in GSTR-3B, as per the invoices of
inward supplies. Hence, the amount of Rs. ……. (CGST Rs. ……. and SGST Rs. …….) is deducted from the
ITC reflecting in GSTR-2A of Rs. …………….

Accordingly, to conclude from above, the Company is reversing the following ITC, reproduced as under:

Particulars IGST CGST SGST Total

Excess ITC availed (due to clerical mistake)
Invoices not reflecting in GSTR-2A but ITC availed in GSTR-3B
Claimed under different head
Total

Further, the Company has reversed the ITC along with interest @ 18% through DRC-03 dated ………
having ARN No. …………. The said DRC-03 is here by annexed as Annexure – 4

We believe that your good-self office will find the above in order. We request you to take note of above
submission and issues the Form ASMT – 12 (i.e. Order of acceptance of reply against the notice issued
under section 61). Further, in case your good office require any clarification, please let us know.

The Assessee assures you the best of co-operation all the time.

Thanking you,

For <<Details of the Assessee>>

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DISCLAIMER:-
(Note: Information compiled above is based on my understanding and review. Any suggestions to improve
above information are welcome with folded hands, with appreciation in advance. All readers are requested to
form their considered views based on their own study before deciding conclusively in the matter. Team
GSTCORNOR® & Author disclaim all liability in respect to actions taken or not taken based on any or all the contents
of this article to the fullest extent permitted by law. Do not act or refrain from acting upon this information without
seeking professional legal counsel.)

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