Basics of GSTR 2B

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Basics of GSTR 2B

Overview of GSTR 2B

The new form GSTR 2B has been introduced on GST Portal.

The GSTR 2B will be available for the month of August 2020 and onwards.

The sample GSTR 2B is also available on the portal for the month of July 2020.

Background

ITC matching was one of the main objective of the Government at the time of the introduction of GST.

Originally GSTR 1-2-3 have been proposed but could not be implemented.

The Form GSTR 2A was available but there was no compulsion for matching of ITC.

Rule 36(4) has been introduced with a maximum cap of 110% of ITC as available in GSTR 2A.

New GST return GST RET 1/2/3 with ANX 1 & 2 (similar to GSTR 1/2/3) proposed but not implemented.

To facilitate the implementation of rule 36(4), new static form GSTR 2B has been introduced.

Salient Features of GSTR 2B

No legal provisions for the GSTR 2B till date.

It will be a static form and will be generated on the 12th of next month covering details of ITC for which the supplier has filed a return from the 12th of the previous month to the 11th of the current month.

Eg. GSTR 2B of August’20 will be generated on 12.9.20 and it will cover details of ITC for which GSTR 1/5/6 has been filed by a supplier between 12th August to 11th
September irrespective of the date of the invoice.

ITC on import of goods including import from SEZ will be available in form GSTR 2B. It will be available in GSTR 2B of the month in which import has been made.

It will bifurcate the ITC into Available ITC and Not-available ITC. The not available ITC will be mainly on account of (i) Place of supply and recipients’ state is different and (ii) supplier has filed a return after time limit of section 16(4) i.e. next year September return.

The date of filing of return by the supplier will be reflected in GSTR 2B. It will help to trace the defaulting supplier.

Table 3A will reflect the ITC  available based on Invoices / Debit Notes and Amendments of both. It will cover ITC from registered person, ISD, import of goods and
supplies covered under RCM.

Table 3B will reflect the reversal of ITC required based on credit notes and its amendments.

Table 4 will reflect the details of ITC not available.

The ITC reversal and RCM liability is just indicative and one needs to discharge liability according to books of accounts.

Advantages of GSTR 2B

Easier to comply with rule 36(4) and calculate eligible ITC.

No need to download GSTR 2A of previous months.

ITC details of Import is also available.

Easy to track suppliers who default in filing of GST returns.

Disadvantages of GSTR 2B

It will be easy for the department to track non-compliance of rule 36(4) which itself is debatable/controversial.

The data in GSTR 2B is just indicative. However, the Authorities will adhere to figures of GSTR 2B.

It will create unwarranted notices/litigation.



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CA Abhishek Doshi
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