GST Advisory on ITC Availability for FY 2020-21

No taxpayer shall receive input tax credit in regard records (invoices and debit notes) for the supply of goods or services (or both) for Financial Year 2020-21 after the due date of furnishing the return for the month of September 2021, according to Section 16(4) of the CGST Act, 2017. The GSTR-3B is due on the 20th of October 2021 for monthly filers and the 22nd or 24th of October 2021 for non-monthly filers, depending on the taxpayer’s state/UT of registration. In light of this, take note of the following:

1. Records (invoices or debit notes) for the Financial Year 2020-21 that are reported in GSTR-1 after the GSTR-3B due date of September 2021 will not appear as “ITC Available” in the recipients’ GSTR-2B. Such records will appear in the GSTR-2B “ITC Not Available” section, and such ITC will not be auto-populated in GSTR-3B.
2. Records (invoices or debit notes) for the Financial Year 2020-21 reported in GSTR-1 after the due date of GSTR-3B in September 2021 would not appear in Table-8A of GSTR-9 of the recipients as “ITC as per GSTR-2A.”

It is requested that taxpayers take note of the above and ensure that their records for the Financial Year 2020-21 are reported on or before the due date of their GSTR-3B for the month of September 2021, or for the quarter of July to September 2021 in the case of quarterly GSTR-3B filers, on or before the due date of their GSTR-3B for the month of September 2021. The receipt of ITC in violation of GST legal provisions may result in legal action by tax administrations.