CBIC – Taxpayers to Submit GST Annual Returns by the Deadline

Dear GST Taxpayer, For the Fiscal Year 2022–2023, kindly submit your Annual Return using Forms GSTR-9 and GSTR-9C. The 31st of December, 2023 is the deadline for filing Forms GSTR-9 with 9C. Forms GSTR-9 and GSTR-9C that are filed beyond the deadline will be penalized.

Taxpayers who must submit Form GSTR-9

All GST taxpayers with a combined revenue above two billion rupees (for the fiscal year 2022–2023), with the exception of:

1. Input Service Provider

2. The TDS Deductor

gst

3. TCS Collector

4. Non-Resident Taxable Individual

5. Taxable Non-Resident Individual

Read More: ITR submission was overlooked? The deadline for late filing income tax returns is December 31st.

Taxpayers who are required to file FORM GSTR-9C

During F.Y. 2022–2023, taxpayers whose aggregate annual turnover exceeds Rs. 5 crore are required to file an annual return in FORM GSTR-9 along with a self-certified reconciliation statement in FORM GSTR-9C.

 

MISMATCH BETWEEN GSTR 2A, GSTR 2B AND GSTR 8A

The details of GSTR-2A, GSTR-2B, and GSTR-8A, and how the discrepancies between these forms can lead to issues for taxpayers.

 

1. GSTR-2A

GSTR-2A is an auto-generated statement of inward supplies. It contains details of purchases made by a taxpayer during a specific tax period as reported by their suppliers in their GSTR-1 returns. In simpler terms, it is a reflection of all the supplies that your suppliers have declared they made to you during a given month. It acts as a preliminary record for you to verify against your own purchase records.

 

2. GSTR-2B

GSTR-2B is also an auto-generated statement of inward supplies, similar to GSTR-2A. However, GSTR-2B is not based on real-time supplier data. It is a static statement generated on a monthly basis and provides a consolidated view of input tax credit (ITC) available to the recipient. It includes information from GSTR-1, but it is designed to be used for informational and reference purposes, and it helps taxpayers reconcile their input tax credit.

 

 

GSTR mismatch

 

3. GSTR-8A

GSTR-8A is the statement of tax collected at source (TCS) and TCS credit. It contains details of TCS collected by an e-commerce operator during a particular period. This form is applicable to e-commerce operators who are required to collect tax at source on behalf of sellers on their platform. It’s different from GSTR-2A and GSTR-2B, as it deals specifically with tax collection at source and not general purchases.

 

Discrepancies and Mismatches:

Now, if transactions from GSTR-2A are not appearing in GSTR-8A, there could be a few reasons for this:

 

1. Supplier Errors

Sometimes, suppliers might forget to report transactions in their GSTR-1, leading to missing entries in your GSTR 2A.

 

2. Timing Differences

The timing of when the supplier files their GSTR-1 and when you file your GSTR-2A might cause a mismatch, especially towards the end of the return-filing period.

 

3. Data Processing Issues

Technical glitches or processing delays in the GSTN (Goods and Services Tax Network) system could also result in discrepancies between forms.

 

4. Incorrect Reporting

Either the supplier or the recipient might make mistakes while reporting transactions, leading to mismatched entries.

 

5. Impact on Assessee

The discrepancies between GSTR-2A and GSTR-8A, along with other forms, can have several negative implications for the taxpayer:

 

a. ITC Mismatch

Mismatches between GSTR-2A and GSTR-8A can lead to inconsistencies in input tax credit claims, which can result in the reduction of available credit.

 

b. Reconciliation Challenges

Taxpayers have to spend additional time and effort reconciling these discrepancies, which can be time-consuming and resource-intensive.

 

GSTR mismatch

 

c. Interest and Penalties

If there’s a mismatch and you claim more ITC than what is actually available, you might have to pay interest on the excess claimed amount.

 

d. Compliance Issues

Mismatched data can lead to non-compliance with tax regulations, which might attract penalties or other legal consequences.

 

 

Read More: A Complete Overview of GSTR 2A Reconciliation

 

 

e. Cash Flow Impact

If there are delays or discrepancies in claiming ITC, it can impact your cash flow and working capital.

 

To address these issues, it’s crucial for taxpayers to regularly reconcile their purchases against the details in GSTR-2A, GSTR-2B, and other relevant forms. They should also communicate with their suppliers to rectify any discrepancies and ensure accurate reporting to avoid unnecessary complications and financial burdens.

A Complete Overview of GSTR 2A Reconciliation

GSTR 2A reconciliation is a crucial process that helps different types of businesses to match the invoices and identify if there is any discrepancy. The process of GST reconciliation primarily includes matching the data that the suppliers upload with the purchase date of the recipient. Therefore, businesses must undertake the process of GST reconciliation.

 

 

What Is GSTR 2A?

Form GSTR 2A refers to the system-generated dynamic tax return related to the purchase. It is a read-only document that lists the invoices from various vendors during a month. This document informs a business about the invoice details of its sellers.

 

 

 

 

GSTR 2A Reconciliation- Meaning

Generally, reconciliation refers to the comparison between the data entries sets, which helps identify the differences or variances. It allows you to rectify unintentional errors. Under taxation, reconciliation is significant as it can give rise to a situation where you pay the excess or less tax.

 

 

It is a process of matching invoices found in the GSTR 2A with those mentioned by a business in its books. This process allows businesses to compare the invoices and find out the discrepancy between the invoices. The process involves comparing the data uploaded by the suppliers with the recipient’s data.

 

 

It includes matching the GSTR-2A auto-populated from the data of the suppliers and the data recorded by the one who obtains the supplies. This helps ensure that the transactions that occur in a specific period are documented safely.

 

 

There are several reasons why the reconciliation process is crucial. It allows a person to ensure that no input tax credit is lost on the invoices where the vendor has specified their GST liability but the buyer has not claimed the credit in their returns.

 

 

The GSTR 2A Reconciliation process also permits you to identify the missing invoices in GSTR 2A. You can then take the steps required to upload the missing invoices from the supplier. Further, in the case where invoices have been uploaded, but the values are not accurate, then in such cases reconciling allows you to take immediate steps to rectify the error. It also helps one avoid the claim of ITC on similar invoices multiple times.

 

 

Types Of Mismatches That Can Be Identified In The Reconciliation Process

The different types of mismatches that can be found during the reconciliation process include the following-

  • Difference in the ITC amount displayed in the GSTR 3B and GSTR 2B or 2A;

 

  • The discrepancy in the sales details in GSTR 3B and GSTR 1;

 

  • Variations in the provisional credit claimed under the CGST Rule 36 (4), and the actual credit claimed according to GSTR 2B in different return periods;

 

  • Variation in ITC values in GSTR 2B with ITC in books of accounts;

 

  • Variation in sales details in the books of accounts when compared with GSTR 1 auto-populated from the e-invoicing system;

 

  • Difference in tax payable when auto-populated GSTR 3B is compared with the books of accounts;

 

If these differences are found, it can lead to the issuance of notice to the taxpayers. It may even lead to the suspension of GST registration.

 

 

GSTR 2A Reconciliation

 

 

Major Causes Behind Mismatches

There may be multiple reasons behind such mismatches. We have discussed some popular ones below-

  • One of the reasons could be that the vendor declared the liability, but credit is not availed in the GSTR. The credit should be availed as soon as possible.

 

  • Another case could be where the vendor has not declared the liability on the supplies executed, but the entity has availed of the credit on the procurement in the GSTR. To avoid such scenarios, businesses are required to follow up with the vendor. Such a situation may lead to the disallowance of such credits;

 

  • Another cause for the mismatch could be the mismatch between the declaration of liability by the vendor and the credit availed. In such cases, the main cause needs to be identified, and an immediate reconciliation process should be adhered to.

 

  • There could be a situation where there is some mistake in the details provided. There could be a mismatch in the GSTIN field of the supplier or recipient. There may be a mismatch in the invoice number and date, etc.

 

 

GSTR 2A Reconciliation- Challenges In Reconciliation Process

The process of GST reconciliation sometimes becomes challenging. It becomes an arduous task and consumes a lot of time. Some of the challenges faced by people while going the complete exercise have been discussed below-

  • There may be certain bugs or glitches on the website that can hamper the entire process of reconciliation;

 

  • Another challenge is related to manual check that needs to be done. In case of any discrepancy, one may need to go back from the website to the books and vice versa, which will take a lot of time to complete the process;

 

  • If you have to reconcile a huge number of entries, you might fill in incorrect details or miss some important invoices. This will increase your work burden;

 

  • The lack of crucial filters can pose a challenge that could have helped draw insights from the reports for analysis. In such cases, having an automated reconciliation solution can help in saving the time and energy required to ensure monthly compliance.

 

 

Why Did The GSTR 2A Reconciliation Process Become Necessary?

Till 2019, many business owners did not consider this process necessary. This was because the entries made in the GSTR 2A didn’t affect the tax liability or the taxpayers’ assets. Therefore, the taxpayers could afford to ignore the same.  However, there has been a definite shift in people’s perspectives. With Rule 36 amendments, GSTR 2A reconciliation has become relevant. Now it has become crucial for businesses to go through the reconciliation process.

 

 

Another reason why it has become crucial is that the GST department has sent notices to various taxpayers. The department made recurring queries about the reconciliation of GSTR 2A. The department claimed that certain businesses had received undisclosed goods or services from different vendors. Many didn’t know they were required to file multiple returns, which caused many to file returns incorrectly. This affected GSTR 2A. Thus, when taxpayers started getting notices from the department, people also started handing over a proper GSTR 2A reconciliation.

 

 

There is one more reason that raises the significance of this process. The refund claimants also consider the reconciliation process as, under the GST legislation, those businesses engaged in the export business and other supplies are eligible to claim tax refunds. In certain scenarios, taxpayers are required to show the concerned department that they have made tax payments on the inward supplies. This can be done through the respective entries made in GSTR 2A.

 

 

Hence, export businesses ensure that the purchases are reflected on the GSTR 2A without missing out on them. The reconciliation process allows the business to follow up with the suppliers and ensure that the GSTR 2A is updated.

 

 

 

GSTR 2A Reconciliation

 

 

Process Of GSTR 2A Reconciliation

The following process should be followed to ensure that the reconciliation is done properly-

  • Download the GSTR 2A. It can be downloaded by logging into the respective account of taxpayers on the GST portal.

 

  • Next, reconcile the said form with purchases and in case of any mismatch, take the necessary action;

 

  • Match the ITC according to the purchases recorded in the books of accounts with the ITC in accordance with the GSTR 2A;

 

  • Review the reasons behind such a mismatch and reconcile the ITC;

 

  • The taxpayer is required to file a GSTR 3B with the correct ITC amount;

 

  • GSTR 2A should be reconciled with GSTR 3B and in case of mismatch, take appropriate action;

 

  • In case the GSTR 3B for the specific period has already been submitted, match the ITC according to the GSTR 3B with the ITC in accordance with the GSTR 2A;

 

  • Again evaluate the cause for such mismatch, if any. Take appropriate action to reconcile the ITC.

 

 

Read More: LATE INCOME TAX RETURN FILING: PENALTIES & DEADLINES

 

 

Takeaway

GSTR 2A reconciliation may seem a straightforward process with automation assistance, but it is time-consuming. The taxpayers must constantly connect with the vendors to make changes in the returns filed. It can become challenging for businesses dealing with thousands of invoices in a month. Hence, businesses are advised to reconcile the returns data regularly under the GST.