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Dear Professional Colleagues,

Greetings of the Day !

The Central Board of Indirect Taxes and Customs issued Circular No. 183/15/2022-GST dated December 27, 2022, regarding Clarification to deal with the difference in Input Tax Credit (ITC) availed in FORM GSTR-3B as compared to that detailed in FORM GSTR-2A for FY 2017-18 and 2018-19. 

Background/ Issues

During the initial period of implementation of GST, during the financial years 2017-18 and 2018-19, in many cases, the suppliers failed to furnish the correct details of outward supplies in their FORM GSTR-1, which has led to certain deficiencies or discrepancies in FORM GSTR-2A of their recipients. However, the concerned recipients may have availed input tax credit on the said supplies in their returns in FORM GSTR-3B.

Also, FORM GSTR-2A could not be made available to taxpayers on the common portal during the initial stages of the implementation of GST.


S. No.   



Where the supplier has failed to file FORM GSTR-1 for a tax period but has filed the return in FORM GSTR-3B and paid taxes. 

Differences in ITC claimed in FORM GSTR-3B and that available in FORM GSTR-2A may be handled by following the procedure provided below. 

Where the supplier has filed FORM GSTR-1 as well as return in FORM GSTR-3B for a tax period, but has failed to report a particular supply in FORM GSTR-1. 

Where supplies were made to a registered person but supplier has wrongly reported the said supply as B2C supply. 

Where the supplier has filed FORM GSTR-1 as well as return in FORM GSTR-3B for a tax period, but he has declared the supply with wrong GSTIN of the recipient in FORM GSTR-1. 

Follow the same process as mentioned for the above cases.


In addition, the proper officer of the actual recipient shall intimate the concerned jurisdictional tax authority of the registered person, whose GSTIN has been mentioned wrongly, that ITC on those transactions is required to be disallowed, if claimed by such recipients in their FORM GSTR-3B. However, allowance of ITC to the actual recipient shall not depend on the completion of the action by the tax authority of such registered person, whose GSTIN has been mentioned wrongly, and such action will be pursued as an independent action. 


Process of checking ITC

The proper officer shall first seek the details from the registered person regarding all the invoices on which ITC has been availed by the registered person in his FORM GSTR 3B but which are not reflecting in his FORM GSTR 2A. He shall then ascertain fulfillment of the following conditions of Section 16:  

i) that he is in possession of a tax invoice;  

ii) that he has received the goods or services or both;

iii) that he has made payment for the amount towards the value of supply, along with tax payable thereon, to the supplier. 

(iv) In order to verify the condition of Section 16(2)(C), that tax on the said supply has been paid by the supplier, the following action may be taken by the proper officer:  

- In case, where the difference between the ITC claimed in FORM GSTR-3B and that available in FORM GSTR 2A of the registered person in respect of a supplier for the said financial year exceeds Rs 5 lakh, the proper officer shall ask the registered person to produce a certificate for the concerned supplier from the Chartered Accountant, certifying that supplies in respect of the said invoices of supplier have actually been made by the supplier to the said registered person and the tax on such supplies has been paid by the said supplier in his return in FORM GSTR 3B.

-  In cases, where the above difference is upto Rs 5 lakh, the proper officer shall ask the claimant to produce a certificate from the concerned supplier itself.  


Clarifications given are applicable to the bonafide errors committed in reporting during FY 2017-18 and 2018- 19. Further, these guidelines are clarificatory in nature and may be applied as per the actual facts and circumstances of each case and shall not be used in the interpretation of the provisions of law. 

These instructions will apply only to the ongoing proceedings in scrutiny/audit/ investigation, etc. for FY 2017-18 and 2018-19 and not to the completed proceedings. However, these instructions will apply in those cases for FY 2017-18 and 2018-19 where any adjudication or appeal proceedings are still pending.

Hope you find it interesting and useful to read.

For any clarification/ feedback, feel free to write us at

Best regards,



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© -2022 AMRG & Associates All Rights Reserved. This document has been written for the general interest of our clients and professional colleagues and is subject to change. This document is not to be construed as any form of solicitation. It is not intended to be exhaustive or a substitute for legal advice. We cannot assume legal liability for any errors or omissions. Specific advice must be sought before taking any action pursuant to this document.

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