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Form GSTR-2B under GST Scenario

Sep 18, 2020 by B S Seethapathi Rao in GST Compliances

Table of Contents

Legality and Scope of Form GSTR-2B framed by GSTN as per recommendations of sub-committee of GST Council under GST Scenario.

GSTN has framed and enabled Form GSTR-2B through their Common portal recently, after referred many doubts and confusion started in our mind as a tax practitioner. What is the necessity to generate and proposed to enabled through Common Portal by GSTN, because we have already followed many compliances under GST Law and upload the data and filed various returns through Common Portal? In my understanding, the GST Council thinking about revenue leakage by way FAKE ITC claims by some of the FAKE taxpayers all over India, so, they want to arrest such leakage, so, they have discussed internally and constituted a sub-committee on return filling or discusses various issues including simplification of filing monthly returns by taxpayers including modifications in returns, related changes in LAW, RULES, and Formats applicable and at the same time thinking about Linkin of Inward supply details upload by the supplier through different forms like Form GSTR-1, Form GSTR-5 and Form GSTR-6 through GSTN Common Portal monthly or quarterly basis to know the eligibility of ITC by the recipient before filing GSTR-3B. Based on suggestions from Sub-Committee, GSTN has framed Form GSTR-2B on a trial run basis from Aug’2020.

Herewith I have discussed table-wise details of Form GSTR-2B and compare with present Form GSTR-2A with Form GSTR-2B for clarity and difference between both forms under the GST scenario. So, Form GSTR-2B is an auto-drafted Input Tax Credit statement which will be generated for every registered person on the basis of the information furnished by the supplier through Form GSTR-1, Form GSTR-5, and Input Tax Credit received through Form GSTR-6. Form GSTR-2B statement will indicate the availability of ITC to the registered person against each document filed by supplier and ISD dealer including information relating to the import of goods from the ICEGATE system and also inward supply of goods from SEZ units/Developers.

Form GSTR-2B for a month contains all documents filed by suppliers between the due dates of furnishing of Form GSTR-1 for the previous month to the due date of furnishing of Form GSTR-1 for the current month. i.e. for the month of July 2020 documents filed by suppliers from 12th July 2020 to 11th August 2020. Instances where the return due date is later than the date of generation of GSTR-2B and it is advised to avail Input Tax Credit on a self-assessment basis.

The documents would reflect in the next open Form GSTR-2B of the recipient irrespective of the date of the document. For Example, Invoice no.1 dated 15.04.2020 uploaded in July 2020 return filed on 11th August 2020, it would be reflected in Form GSTR-2B of July 2020 generated on 12th Aug 2020 and not in Form GSTR2B of April 2020.

The following are the advantages of Form GSTR-2B, the taxpayers are referred before avail of Input Tax Credit in Form GSTR-2B as per GSTN Common Portal information:

1. Form GSTR-2B is a summary report for Input Tax Credit available and not available for the month helps the management to have an overview of Input Tax Credit for the month.
2. Table -4 of Form GSTR-2B provides details for Input Tax Credit not available to claim ITC by the recipient for the month.
3. Data of ICEGATE available relating to the import of goods from overseas and inward supplies from SEZ to ensure Input Tax Credit has not been missed out.
4. Repetitive download of the previous month’s data would not be required as in Form GSTR-2A.
5. Form GSTR-2B shown a clear picture of Input Tax Credit to be available for the tax period of Recipient.
6. As per Rule 36(4) of the CSGT Rules,2017, It clearly showed about the reconciliation of Input Tax Credit ledger and invoice details uploaded in Form GSTR-1 by the supplier under GST Scenario.
7. There is no requirement of reconciliation to be performed on year to date basis every month as the Form GSTR-2B report is static. Although, from October 2019 to June 2020 Year to date reconciliation may be required ( as per my opinion),

Comparison Form GSTR-2B with Form GSTR-2A:

Details	Form GSTR-2B	Form –GSTR-2A
Basic Future of the Forms	Form GSTR-2B is a static form i.e. details of supplies uploaded by the vendors after the cut-off date considered in the subsequent period.	Form GSTR-A is a dynamic i.e. details of supplies uploaded by vendors are updating to such a month without utilizing a cut-off date.
Data captured from the GST return forms	Data captured from Form GSTR-1, Form GSTR-5, Form GSTR-6, ICEGATE system only but not information relating to TDS and TCS deductions made by the recipients as per GST Law,2017.	Data captured from Form GSTR-1, Form GSTR-5, Form GSTR-6, Form GSTR-7, Form GSTR-8, ICEGATE system and Bill of Entry details recently uploaded by the relevant department.
Viability of Forms	Form GSTR-2B is very useful in Input Tax Credit reconciliations and to identify compliant/ non-compliant vendors ( Particularly Rule 36(4) of GST Rules,2017.	All GSTR-2A credits are considered as vendors may delay in filing of returns. So, it is very difficult to ensure information relating to creditors.
Features are available in the Forms	In Form GSTR-2B “Online portal has provided various features listed subsequently”. So, in my opinion, it is trail run. so, GSTN does not mention about additional features in their portal.	In Form GSTR-2A, not available of all the features.

Detailed discussions of each Table of GSTR-2B: Form GSTR-2B consists of Part-A, Part-B information relating to the availability of Input Tax Credit, Non-availability of Input Tax Credit, and Reversal of Input Tax Credit between B2B Transactions.

Table-3, Part – A of Form GSTR-2B about Input Tax Credit available.

S.No.	Table of Form GSTR-2B	Particulars	Table of Form GSTR-3B	Remarks
1	Section-I	The details of invoices and debit notes including amendment filed by the supplier in Form GSTR-1 and Form GSTR-5	Table – 4(A)(5) of Form GSTR-3B	This table does not contain Reverse Charge Mechanism supplies and negative value due to amendment disclosed in Table 4(B)(2)
2	Section-II	The details of invoices including amendment filed in Form GSTR-6.	Table – 4(A)(4) of Form GSTR-3B.	If any negative value due to amendment to be disclosed in Table- 4(B)(2).
3	Section-III	The details of invoices and debit notes pertaining to supplies on which tax is to be paid on RCM basis declared and filed by the supplier in Form GSTR-1	Table – 3.1(d) & Table- 4(A)(3)	This table does not contain credit on the import of services and unregistered suppliers.
4	Section-IV	This table contains payment of IGST on import of goods from the overseas and inward supply of goods from SEZ units/developers on the bill of entry including the amendment.	Table- 4(A)(1) of Form GSTR-3B	a). This table updated on a near real-time basis from the ICEGATE. b). ICEGATE reference date is the date from which input tax credit to be availed. However, the difference between the BOE date and ICEGATE reference date is not provided. c). Information on certain imports such as courier imports may not be available. d). This form details will be available from Aug 2020 onwards. i.e. 12th September 2020 onwards only.