Input Tax Credit Reversal under GST

Input Tax Credit Reversal under GST

ITC Reversal under GST


While paying taxes to the Government, businesses can use the credit of GST paid on the purchases like raw materials/services used for manufacturing or selling products. It is known as an Input tax credit (ITC). If the input tax credit is wrongly claimed, then it should be reversed by making the payment to that extent next month.

The article dives into the meaning, purpose, and cases under which ITC reversal is required.

What does the reversal of ITC mean?

In certain situations, even if the basic conditions for claiming ITC are satisfied, ITC claims must be reversed. Reversal of ITC means the credit of inputs utilized earlier would now be added to the output tax liability, effectively nullifying the credit claimed earlier. Depending upon when a such reversal is done, payment of interest may also be required. 

Specific conditions for ITC reversal

The ITC is required to be reversed under various scenarios defined in the Act. Some of those scenarios are summarised below:  

Circumstances When is ITC reversal required
The recipient fails to pay consideration to the supplier (whether fully or partly) for a particular supplyWithin 180 days from the date of issue of the invoice.
Depreciation under the Income Tax Act has been claimed on the GST component of capital goods purchasedReversal is required at the time of closing books of accounts for that financial year.
Inputs have been used to make an exempt supply Periodically (monthly/yearly) using a formula given below for common credits if inputs are exclusively used for making exempt supply, then reverse it as and when identified to have been claimed.
Inputs have been used for manufacturing supplies some of which were used for non-business or personal purposesPeriodically (monthly/yearly) using a formula given below for common credits (if inputs used are exclusively attributable to a supply used for consumption, reverse such ITC upon identifying as having been claimed).
Cancellation of GST registrationWhile filing form REG-16 under various situations explained in detail in our article on the cancellation of GST registration. 
Reversal of 50% of ITC by banking and other financial companies under special rulesAt the time of filing regular returns.
Reversal of 5/6th of the ITC taken on gold dores in stock as of 1st July 2017At the time of supply of either the gold dore bar or the gold/gold jewelry. 
ITC has been availed on ‘blocked credits’At the time of filing regular returns up to the date of filing annual returns.
Inputs used in goods that were lost, destroyed, stolen, etc.At the time of filing the regular returns about the month in which such loss had occurred. 
Inputs used in goods that were given out as free samplesAt the time of filing the regular returns about the month in which such free samples were given out.

Calculation of ITC under various rules

Let’s check out the different rules prescribed for calculating the amount of ITC to be reversed:

Before we proceed to discuss each rule, the total ITC can be divided into the following parts:

Before we proceed to discuss each rule, the total ITC can be divided into the following parts:

Before we proceed to discuss each rule, the total ITC can be divided into the following parts:

Specific credit: ITC that can specifically be attributable to a supply – either taxable, non-taxable, or supply consumed for personal use.

Treatment: Separate such ITC amount from the total ITC since it can be easily identified. 

  • The amount of ITC that is only directly attributable to a particular taxable supply can be utilized. It is available in the electronic credit ledger.
  • Taxpayers must reverse the amount of ITC directly attributable to a particular supply that is non-taxable/used for personal consumption, only when wrongly availed.

Common credit: ITC amount that cannot be attributable to a specific supply but is used for partly making both the taxable and non-taxable supplies/supplies used for personal consumption. 

Treatment: 

  • Taxpayers must identify and reverse the proportionate ITC amount to the extent of supplies that are non-taxable/used for personal consumption.
  • The remaining ITC left is eligible for the claim.

Rule 42 and 43: ITC reversal on the supplies that are exempt or used for personal consumption

The calculation of ITC to be reversed differs for:

  • Inputs or input services- covered by rule 42
  • Capital goods- covered by rule 43

Rule 42: Reversal of ITC on inputs/input services

Step-1: Businesses must first segregate the specific credits that are ineligible for the claim,  from the total ITC as follows:

Variable usedFormulae/ Explanation
TTotal input tax paid credit on inputs and input services
T1Out of ‘T’, the specific credit attributable to inputs/input services intended to be used for non-business purposes
T2Out of ‘T’, the amount of input tax attributable to inputs/input services intended to be used exclusively for effecting exempt supplies
T3Out of ‘T’, the amount of input tax deemed as ‘blocked credits’ under section 17(5)

Note: T1, T2, and T3 must be reported in GSTR 3B at a summary level for every tax head

Step-2: Reduce T1, T2, and T3 from the total ITC and derive the common credit as follows:  

C1ITC credited to electronic credit ledger T – (T1 + T2 + T3)
T4Specific credit on inputs/input services attributable exclusively to making taxable supplies. This would also include zero-rated supplies like exports and supplies to SEZ.
C2Common credit C1 – T4

ITC on the inputs that are assumed to have been used partly in making taxable supplies and partly in making exempt supplies or used for a non-business purpose. 

Step-3: Compute the amount of ITC to be reversed out of the common credit as follows:

D1The ITC attributable towards exempt supplies out of common credit: (E÷F) × C2

Where: 
E: Aggregate value of exempt supplies during the tax period 
F: Total turnover in the State of the registered person during the tax period

Note: For building construction services, (E÷F) will be calculated on a project basis

where:
– E stands for aggregate carpet area of exempt construction project or apartments sold after construction is over
– F stands for aggregate carpet area of the apartments in the project
D2Deemed to be ITC attributable for non-business purposes out of common credit: 5% of C2
C3Remaining eligible ITC out of common credit: C2 – (D1 + D2)

Based on the above calculations, D1 and D2 will be the ITC that needs to be reversed.  

Illustration:  

Consider the following scenario for July 2020 about supplies made in Karnataka:

ParticularsAmount (in Rs)
Total ITC available (T)1,50,000
ITC on inputs attributable to supply used by Director for personal use (T1)
7,500
ITC on inputs to be used exclusively for making exempt supply (T2)15,000
Blocked credits (for example, GST portion paid in respect of taxi service obtained) (T3)4,500
ITC on inputs used exclusively for making taxable supplies (T4)
1,05,000
The aggregate value of exempt supplies made in July (E)2,25,000
Total turnover in Karnataka (F)30,00,000

Solution: 

C1 = T – (T1+T2+T3);  C1 = 1,50,000 – (7,500+15,000+4,500), therefore, C1 = 1,23,000.

The common credit C2 = C1 – T4 , i.e., C2 = 1,23,000-1,05,000 , i.e., C2 = 18,000.

D1 = (E÷F) × C2 , i.e., D1 = (2,25,000 ÷ 30,00,000) × 18,000 , i.e., D1 = 1,350.

D2 = 5% of C2 , i.e., D2 = 900.

C3 = C2 – (D1 + D2) , i.e., C3 = 15,750.

So, out of the originally available ITC of Rs. 1,50,000, only C3 (Rs. 15,750) and T4 (Rs. 1,05,000) were credited ultimately to the electronic credit ledger and D1 (Rs. 1,350) and D2 (Rs. 900) were required to be reversed. 

Rule 43: Reversal of ITC on capital goods

The first step is to find out if the ITC falls under the following criteria:

  • The ITC is about capital goods that have been used exclusively for non-business purposes or for making exempt outward supplies. OR
  • The ITC is about capital goods that have been used exclusively for making supplies other than exempt supplies. Note that this would include zero-rated supplies too.

In case the ITC falls under category ‘A’ above, then credit will not be allowed in respect of the same. In case the ITC falls under category ‘B’ above, then credit will be allowed and taken to the electronic credit ledger. The useful life of capital goods is taken to be five years from the date of invoice.

This is done so that in case the capital goods were covered in category ‘A’ or ‘B’ as mentioned earlier and are now not covered under either category, then the ITC would be called ‘common credit’ or ‘Tc’ and 5% would have to be deducted from this common credit for every quarter or part quarter for the time it was covered in the category ‘A’ or ‘B’.  

The useful life of the capital goods has been taken as 5 years, but our filing period relates to the supplies made/received in a particular month, so we will first find the ITC attributable to a month by dividing the credit by 60. 

Variable usedFormulae / Explanation
TmTc ÷ 60 Amount of ITC attributable to a tax period (a month) on common capital goods during their useful life
TrAggregate Tm of all those capital goods which have useful life remaining at the beginning of the tax period
TeThis is the common credit attributable towards exempted supplies, which is calculated as follows: (E ÷ F) × Tr

Where:
-E: Aggregate value of exempt supplies made during the tax period
-F: Total turnover in the State of the registered person during the tax period

Note: For building construction services, (E÷F) will be calculated on a project basis

where:
-E stands for aggregate carpet area of exempt construction project or apartments sold after construction is over
-F stands for aggregate carpet area of the apartments in the project

Thus, Te calculated above will be the ITC in respect of capital goods that are required to be reserved or added to the output tax liability. Note that the above calculations would slightly differ if the supply is like services covered under Paragraph 5(b) of Schedule II of the CGST Act. 

Illustration: 

A company operating in Karnataka had availed the following ITC on various capital goods purchased in July 2020:

ParticularsAmount (in Rs)
ITC on Machine A (used exclusively in the supply of exempt goods)1,50,000
ITC on Machine B (used exclusively in the supply of taxable goods)9,00,000
ITC on Machine C (used exclusively for non-business purposes)20,000
ITC on Machine D (used partly in the supply of taxable and exempt goods)4,50,000

The company also made the following type of output supplies in Karnataka in July:

Turnover about exempt supplies: Rs. 20,00,000
Turnover about taxable supplies: Rs. 80,00,000 

Solution: 

ITC on machine A and C will not be credited to the electronic credit ledger (1,50,000+20,000 = 1,70,000). 
ITC on machine B will be credited to the electronic ledger: Rs. 9,00,000 
ITC on machine D will also be credited to the electronic credit ledger: 

Tc = 4,50,000 

Tm = Tc ÷ 60 = 7,500 which is also Tr in this case.

The amount of ITC to be reversed for the month of July, 2020 would be: = (E ÷ F) × Tr = (20,00,000 ÷ 80,00,000) × 7,500 = 1,875 

Thus, the total ITC credited to the electronic ledger for July 2020 = Rs. 10,70,000 and the total ITC reversed for July 2020 = Rs. 1,875  

Rule 44: Reversal of ITC in case of cancellation of GST registration or switches to composition scheme

This rule aims to reverse all the ITC that has been availed by a registered person if he chooses to pay tax under the composition scheme or his registration gets canceled for any reason. 

The calculation is done as follows:

  • For inputs held in stock or contained in semi-finished goods and finished goods in stock, the ITC must be reversed is calculated proportionate to corresponding invoices on which credit was taken. Thus ITC will be allowed only up to the time the registered person switches to the composition scheme or on cancellation of registration.
  • In the case of capital goods, ITC availed will be based on the useful life (in months) and shall be computed on a pro-rata basis. Thus ITC for the remaining useful life of the asset must be reversed while switching over to the composition scheme or on cancellation of registration.

Rule 44A: Balance transitional ITC to be reversed on 1st July 2017 for gold dore bars

This rule relates to ITC taken under the transitional provisions of the CGST Act. 

It is based on CENVAT credit available under the earlier scheme of taxation in respect of additional duty of customs (section 3(1) of the Customs Tariff Act, 1975) paid for the importation of gold dore bars.

Where stock of such gold dore bar (raw material) or gold jewelry (final product) lies with the taxpayer on 1 July 2017, the ITC will be restricted to 1/6th of the credit availed in respect of such gold dore bar.

Hence, 5/6th of the credit availed must be reversed at the time of supply of either the gold dore bar or the gold/gold jewelry made out of it.

Reporting of ITC reversal in GSTR-3B

The amount of ITC reversal needs to be calculated by the taxpayer himself and filled up in Table 4B of GSTR-3B. The ITC reversed that needs to be reported is of two types – 

  • ‘As per rules 42 & 43 of CGST/SGST Rules’, where the ITC attributable to exempt or non-business supply is required to be calculated by us using the formula mentioned earlier and entered in this field – thus this field will not be auto-populated; and
  • ‘Others’, where ITC reversal due to other circumstances will have to be reported; 

Reporting of ITC reversal in GSTR-9

GSTR-9 (annual return) will also need to be filled up with details regarding ITC reversed for the whole year. Wherever possible, the details will be auto-filled based on the data entered in the monthly form GSTR-3B but changes can be made by the taxpayer wherever required.

Table 7 contains the details of ITC reversed and ineligible ITC for the financial year. The relevant details need to be provided for the whole year accordingly.

Created & Posted By Ashu
CA  Article at TAXAJ

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