As any GST practitioner will admit, the real complexity of GST compliance does not lie in monthly GSTR-3B filings, but in accurately mapping the entire year’s tax positions into the GSTR-9 Annual Return. The core challenge is not just arithmetic—it is classification. The placement of Input Tax Credit (ITC) across tables depends on when the invoice was issued, when it was claimed, when it was reversed, and when it was reclaimed.
To eliminate confusion, the reporting logic below distills 13 common scenarios based on the interplay between invoice dates, claim periods, reversals, and subsequent reclaims.
Spillover ITC (FY 2023–24 Invoices Considered in FY 2024–25)
This is one of the most litigated and misunderstood reporting segments. With the introduction of Table 6A1, the placement of spillover credits has been redefined.
Scenario 1: Reclaim of Previously Reversed ITC
- Invoice: FY 2023–24
- Claimed & Reversed: FY 2023–24
- Reclaimed: FY 2024–25
Report In: Table 6A1 only
(No reporting in Table 6H)
Scenario 2: Delayed First-Time Claim
- Invoice: FY 2023–24
- Claimed for the first time: FY 2024–25
Report In: Table 6A1
Scenario 3: Claim, Reverse, Reclaim All in FY 2024–25
- Invoice: FY 2023–24
- Claimed, Reversed, Reclaimed: All in FY 2024–25
Report In: Table 6A1 twice
(The reversal effect is netted off through repeat reporting)
Current Year ITC (FY 2024–25)
These are standard intra-year credits unless affected by reversal cycles.
Scenario 5: Regular Credit
- Invoice & Claim: FY 2024–25
Report In: Table 6B
Scenarios 6 & 7: Reversal and Reclaim in Same Year
- Reversal in FY 2024–25: Table 7
- Reclaim in FY 2024–25: Table 6H
Carry-Forward ITC (FY 2024–25 Invoices Claimed in FY 2025–26)
Where action spills into the next financial year, the reporting shifts to Part V of GSTR-9.
Scenario 10 & 11: Claimed in the Next FY
- Invoice: FY 2024–25
- Claimed: FY 2025–26
Report In: - Table 8C (Mismatch Reconciliation)
- Table 13 (ITC of Previous FY Claimed in Next FY)
Scenario 12: Claim and Reverse in FY 2025–26
Report In:
- Table 8C
- Table 12 (Reversal in Next FY)
- Table 13
The Complex Dual-Impact Case (Scenario 13)
This scenario frequently results in misalignment between books, GSTR-3B, and GSTR-9.
Details
- Invoice: FY 2024–25
- Claimed, Reversed, and Reclaimed: All in FY 2025–26
Reporting Requirement
- Table 8C: For reconciliation adjustments
- Table 12: To show reversal in the next FY
- Table 13: To report ITC availment entries (initial and subsequent reclaim)
The net impact must reflect accurately in the Electronic Credit Ledger.
Key Compliance Insight
The addition of Table 6A1 has significantly improved reconciliation clarity between Table 8A auto-population and Table 6B disclosures. However, it demands stricter categorisation based not only on the financial year of invoice issuance but also the timing of claim and reversal actions.
The correct reporting approach is now governed by a matrix involving:
- Invoice Date
- Year of Claim
- Year of Reversal
- Year of Re-availment
Misclassification in even one of these scenarios may lead to:
- Unexplained variances in Part V
- Excess credit reflection against 8A
- Auditor qualification or departmental queries
Conclusion
Annual return ITC reporting now operates on a cause-and-effect model rather than a straight-line ledger translation. Practitioners must closely track movement of credit across years and align tabular reporting accordingly. With Table 6A1 now central to spillover logic, the discipline of recording and tracking timing differences has become indispensable for accurate GSTR-9 filing.
If you would like, a referral matrix chart or printable compliance sheet can be created for quick desk reference.
Read More: IndiGo Seeks Extension from DGCA to Respond to SCN on Flight Disruptions
