BY VED JAIN AND ASSOCIATES
Accumulated ITC Reversal - pending for Re-
claim
Recently, the GST portal has undergone a significant update aimed at streamlining the electronic credit reversal and
reclaimed statements process.
An advisory has also been issued, which clarifies that taxpayers are required to report their cumulative ITC reversal
(ITC that has been reversed earlier and has not yet been reclaimed) as an opening balance for “Electronic Credit
Reversal and Re-claimed Statement”.
Quarterly Taxpayers
Monthly Taxpayers
Required to report their opening balance up to Q1 of
Required to report their opening balance considering the financial year 2023-24, considering the ITC
the ITC reversal done till the return period of July reversal made till the April-June 2023 return period.
2023
This information is required to be filled by 30th November 2023 by the taxpayers and can be
amended by 31st December 2023, maximum upto 3 times. This statement will be used to validate
the taxpayer's re-claimed ITC in Table 4A(5) and Table 4D(1) of GSTR-3B.
Difference between ITC available in GSTR-2B and availed in
Rule 88D GSTR-3B
If the ITC availed in GSTR-3B exceeds the ITC available in GSTR-2B by a
prescribed amount and percentage, the taxpayer will be intimated of this
variation through the GSTN Portal and their registered email address in
Part-A of Form DRC-01C.
The taxpayer will then have 7 days to either:
• pay the differential amount, along with interest payable under
section 50, through FORM GST DRC-03 and furnish the details
thereof in Part-B of FORM GST DRC-01C, or
• furnish a reply in Part-B of FORM GST DRC-01C
incorporating the reasons of the difference.
If the taxpayer does not respond within the stipulated time period or the
reasons for the difference are not found to be acceptable by the proper
officer, the excess ITC amount shall be liable to be demanded in
accordance with the provisions of section 73 or section 74 of the CGST
Act, 2017.
Difference between liability reported in GSTR-1 and
Rule 88C
GSTR-3B
In case, where the tax liability reported in GSTR 1/IFF exceeds the liability
declared in GSTR 3B, then intimation in part A of Form GST DRC-01B
shall be sent to the registered person.
The taxpayer will then have 7 days to either:
• pay the differential amount, along with interest payable under
section 50, through FORM GST DRC-03 and furnish the details
thereof in Part-B of FORM GST DRC-01B, or
• furnish a reply in Part-B of FORM GST DRC-01B
incorporating the reasons of the difference.
Where neither the liability has been paid nor the reply has been
furnished, then such difference shall be recoverable under section 79 of
the CGST Act, 2017.
Generation of IRN within 30 days
According to the update on the E-Invoice portal, it has been
decided by the Government to impose a time limit of 30 days
on reporting of old invoices on the e-invoice IRP portals for
taxpayers with turnover greater than or equal to 100
crores. This limit will be applicable on debit/credit notes as
well. This change will be implemented w.e.f. November 01,
2023. The notification in this regard is yet to be issued.
Rule 163 Consent-based sharing of information
CBIC vide notification no. 38/2023 has amended the CGST Rules, 2017
A new rule 163 is inserted in the GST rules, applicable w.e.f. October 01, 2023,
The Rule mandates the Consent of the registered person while furnishing the information
for Form GST REG-01, GSTR-3B and GSTR-1.
The registered person shall give his consent for sharing of information only after he has
obtained the consent of all the recipients, to whom he has issued the invoices, credit notes
and debit notes, for sharing such information with the requesting system and where he
provides his consent, the consent of such recipients shall be deemed to have been
obtained.
Miscellaneous updates
Section 37(5) Rule 59(6)
A registered person shall not be allowed to As per rule 59(6), a registered person shall not
furnish the details of outward supplies after be allowed to furnish GSTR1/IFF if:-
the expiry of 3 years from the due date of • GSTR 3B of preceding month has not
furnishing the said details. been furnished.
• Provisions of rule 88C, 88D and 10A
have not been complied with.
Miscellaneous updates
Rule 10A &
Rule 21A(2A)
• As per rule 10A, it is a mandatory requirement to furnish the bank account details on the
common portal before furnishing of GSTR 1/IFF or within 30 days from the date of grant of
registration whichever is earlier.
• Now as per rule 21A(2A), there would be a system-based suspension of registration in case
of contravention of rule 10A. The same shall be revoked once the details of the bank account
have been furnished on the common portal.
Miscellaneous updates
2-Factor Authentication
GST E-way bill system
(2-FA)
• GST E-way bill system issued an update • 2-FA Introduced has been introduced for the safety
dated September 05, 2023 stating that, of the credentials by the GSTN. Every time login
onto the e-invoice / e-way bill portal, an OTP will be
• the taxpayers, having turnover above Rs
sent on the registered mobile no., which will have to
5 Crore, shall use at least 6-digit HSN
be entered to proceed further
code in the e-Invoices as well as e-
• This has been mandated for all the taxpayers with
Waybills.
Aggregate Annual Turnover (“AATO”) exceeding Rs
• This will be made mandatory from 20 Cr., effective from November 01, 2023.
October 01, 2023 in e-Waybill and e- • As of now, taxpayers have the option to defer it for
Invoice Systems. the time being by clicking on the 'Undertaking'
option.
• In both cases, a single OTP will be sent on the
registered mobile no.
Thank You!
Feel free to reach us at:
mail@vedjainassociates.com
GST@vedjainassociates.com
Ved Jain and Associates | Chartered Accountants
