GSTR-2A vs GSTR-3B reconciliation has always been a complex task for the taxpayers, because of many challenges like clerical mistakes in invoice date or invoice number, wrong GSTIN mentioned by supplier, introduction of Rule 36(4), invoice shown by supplier but not available with recipient etc.

Despite of these challenges, now another complex task which is necessary to be complied while filing GSTR-9 (Annual Return) is Table 8 Reconciliation. 

Let us understand what is Table 8 and what are the challenges in its reconciliation.

What is Table 8 of GSTR-9?

Table 8 of GSTR-9 indicates the total eligible input tax credit (“ITC”) from inward supplies available during a particular financial year. It includes all the ITC related to inward supplies including the services received from SEZs but exclude ITC related to import of goods and reverse charge. 

Table 8A – (Table 8B+Table 8C) = Difference i.e., Excess/Short in GSTR-2A 

The contents of Table 8 are displayed below:

The detailed invoice wise detail can be downloaded from GST portal by visiting Services > Returns > Annual Returns > Form GSTR-9 (Prepare Online) > Download Table 8A Document Details. An excel file will be downloaded as a zip file, in case of less documents or else in multiple chunks.

What are the contents of the excel file? 

Sheet-1: Read Me – Instructions on using the functionality 

Sheet-2: B2B Invoices – Details uploaded by suppliers 

Sheet-3: B2BA – Amendment of B2B invoices 

Sheet-4: CDNR – Details of Credit/Debit notes issued by supplier 

Sheet-5: CDNRA – Amendment of Credit/Debit notes

Why Table 8 reconciliation is necessary?

As per Notification No: 56/2019 issued on 14th November 2019, a taxpayer can upload details for the entries in Table 8A to 8D (i.e., the reconciliation of GSTR 2A with GSTR 3B) duly signed, in PDF format in Form GSTR-9C (without the CA certification). Hence, due to this notification, Table 8 reconciliation becomes necessary. But still many taxpayers are facing challenges in uploading this reconciliation in Form GSTR-9C.

Now, lets discuss what are the challenges in this reconciliation.

Challenges in Table 8 Reconciliation 

                                                                                                                                                                     Table 8 compares ITC as per GSTR-2A of the respective F.Y. with ITC availed during the respecting F.Y and also includes ITC related to that F.Y. but availed till due date of GSTR-3B of September of next F.Y. The reasons for Difference if any arising after such comparison is to be listed in columns 8E to 8K as ITC not availed, ITC ineligible, ITC not availed on impot of goods and lastly ITC lapsed in current F.Y. Now, this comparison has many gaps and is not parallel for comparison, hence it seems very challenging in reconciling two unparalleled fields.

Let’s discuss the gaps for better understanding:

What does Table 8A, 8B and 8C constitutes?

Table 8A consist of all the invoices filed by the suppliers in their GSTR-1 along with debit notes and credit notes. However, on analysing data autopopulated in Table 8A with GSTR-2A, it can be observed that Table 8A doesn’t consider ineligible invoices which are available in GSTR2A. These ineligible invoices are classified as under:

• Place of Supply (PoS) is different from the Recipient State in case of Inter-State Transactions
• Reverse Charge Documents uploaded by the Supplier in their GSTR1
• Invoice Date is after the Cancellation of Supplier’s GSTN
• Return Filed by the Supplier after Annual Cut off Date
• Recipient’s GSTN amended by the Supplier in their GSTR1 B2B Amendment

These Invoices were marked as “NO” for ‘ITC available’ by the GSTN itself in the Table 8A Report – Ref Coloumn Q of B2B and Coloumn S of B2BA.

Table 8B consist of ITC availed in GSTR-3B during the respective F.Y except ITC related to reverse charge supplies, ITC related to import of goods and services, Transitional credit and any other ITC. Please refer the Table 6(B) and 6(H) below screenshot for its content:

Table 8C consist of ITC related to the respective F.Y. but reported in GSTR-3B till due date GSTR-3B of September of Next F.Y.

Now after understanding what these tables consist, we can observe that Table 8A consist of Reversals related to credit notes and other reversals as well, however Table 8B & 8C doesn’t include reversals. Further, Table 8B consist of ITC related to reverse charge supplies but Table 8A doesn’t include the same.

Now the aforesaid are some basic reasons for the gaps, and the most important reasons for the gaps can be known only after detailed analysis which are:

• Invoice of previous F.Y, booked in books in current F.Y and simultaneously availed in GSTR-3B of current F.Y won’t reflect in GSTR-2A of current F.Y, but it may reflect in GSTR-2A of previous F.Y.

Lets say, For FY 2020-21, an invoice dated 20.03.2020 having IGST input of INR 10,000 is considered in books in April, 2020 because the services or goods are received in April, 2020. Hence in this case the position will be as follows:

Description	IGST	CGST	SGST
ITC as per GSTR-2A	0.00	0.00	0.00
ITC as per sum total of 6(B) and 6(H) above	10,000.00	0.00	0.00
ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from an SEZ) received during 2017-18 but availed during April to September 2018
Difference [A-(B+C)]	-10,000.00	0.00	0.00

• Invoice related to current F.Y., but recorded in books in next F.Y and simultaneously availed in next F.Y., will reflect in GSTR-2A of current F.Y.

Lets say, For FY 2020-21, an invoice dated 25.03.2021 having IGST input of INR 15,000 is considered in books in April, 2021 because the services or goods are received in April, 2021. Hence in this case the position will be as follows:

Description	IGST	CGST	SGST
ITC as per GSTR-2A	15,000.00	0.00	0.00
ITC as per sum total of 6(B) and 6(H) above	0.00	0.00	0.00
ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from an SEZ) received during 2017-18 but availed during April to September 2018
Difference [A-(B+C)]	15,000.00	0.00	0.00

• GST availed in GSTR-3B, but invoice has been furnished by the suppliers after due date of GSTR-3B of September of next year. In such case, the concerned invoice will be considered in GSTR-2A but not in Table 8A.

Below is the summary of the aforesaid discussion: (strike off text represents that ITC is not considered in that particular table)

Sr. No.	Table 8A	Table 8B + Table 8C
	ITC reversal related to credit notes	ITC reversal related to credit notes
	Reversals other than point (4)	Reversals other than point (4)
	ITC related to invoice of Previous F.Y., but recorded in books in current F.Y. and correspondingly availed in GSTR-3B of Current F.Y. (It is considered in Table 8A of Previous F.Y., if furnished by supplier in GSTR-1)	ITC related to invoice of Previous F.Y., but recorded in books in current F.Y. and correspondingly availed in GSTR-3B of Current F.Y.
	ITC related to invoice of Current F.Y., but recorded in books in next F.Y. and correspondingly availed in GSTR-3B in next F.Y.	ITC related to invoice of Current F.Y., but recorded in books in next F.Y. and correspondingly availed in GSTR-3B in next F.Y. (It will be considered in Table 8B of next F.Y.)
	ITC related to invoice of current F.Y, but availed till cut-off date of September of Next F.Y.	ITC related to invoice of current F.Y, but availed till cut-off date of September of Next F.Y.
	ITC related to invoice of current F.Y, but availed after cut-off date of September of Next F.Y. (It won’t reflect in Table 8A of any F.Y., as it is ineligible ITC)	ITC related to invoice of current F.Y, but availed after cut-off date of September of Next F.Y.
	Any other ITC (other than points 1 to 9)	Any other ITC (other than points 1 to 9)

Irrespective of the above 10 points, there could be some other gaps also, like supplier has not furnished the invoice in its GSTR-1 or has furnished it as B2CS, the invoice is missed by the taxpayer but available in GSTR-2A etc.

Hence after the aforesaid discussion we can arrive at the conclusion that with the above gaps, it will be very challenging for a taxpayer to reconcile Table 8 properly. Thus, government should make some changes in the criteria on the basis of which the figures are auto populated in Table 8A or should add some more reasons in addition to Table 8E to 8K considering the above gaps, so that the process of reconciliation become logical.