ICMAI Handbook on CMA Certifications in GST, Clarifies Key ITC and Certification Provisions [DOWNLOAD NOW]

The Institute of Cost Accountants of India (ICMAI) has released the Handbook on CMA Certifications in GST, a detailed and practice-oriented publication aimed at strengthening professional competence in Goods and Services Tax (GST) certifications. Published by the Tax Research Department of ICMAI, the handbook serves as an authoritative guide for Cost and Management Accountants (CMAs) involved in statutory certifications under the CGST, SGST and UTGST laws.

The handbook comes at a time when GST compliance has become increasingly complex due to frequent amendments, evolving departmental practices, and heightened scrutiny of input tax credit (ITC) claims. It provides structured guidance on certification requirements, legal provisions, professional responsibilities, and audit safeguards, thereby reinforcing the role of CMAs as trusted professionals in the GST ecosystem.

Focus on Section 18 Certifications: ITC in Special Circumstances

A major thrust of the handbook is on certifications under Section 18 of the CGST Act, 2017, which deal with availability, reversal, and transfer of input tax credit in special situations. The publication exhaustively explains certifications required in the following scenarios:

• Section 18(1)(a): Availing ITC on inputs held in stock upon becoming liable for GST registration
• Section 18(1)(b): Availing ITC on voluntary registration
• Section 18(1)(c): Availing ITC on shifting from composition scheme to regular scheme
• Section 18(1)(d): Availing ITC when exempt supplies become taxable
• Section 18(3): Transfer of ITC on change in constitution of business
• Section 18(4): Reversal of ITC on opting for composition scheme or when taxable supplies become exempt

For each provision, the handbook explains the statutory framework, eligibility conditions, time limits, and procedural requirements, with specific reference to Rule 40 of the CGST Rules and the mandatory filing of Form GST ITC-01.

Certification Threshold and Professional Mandate

A critical compliance aspect highlighted is that certification by a practicing CMA or Chartered Accountant becomes mandatory when the aggregate ITC claim exceeds ₹2 lakh, as prescribed under Rule 40(1)(d). The handbook underlines that such certification is not a mechanical exercise but a limited assurance engagement, requiring professional judgment, verification, and ethical responsibility.

The publication clearly demarcates management responsibility and practitioner responsibility, stressing that while preparation of stock statements and declarations rests with the taxpayer, the certifying professional must conduct a thorough examination of books, invoices, stock records, and computation methodologies before issuing the certificate.

Detailed Guidance on Stock, Capital Goods and Valuation

The handbook provides in-depth clarity on:

• Verification of inputs held in stock and inputs contained in semi-finished and finished goods
• Application of the one-year invoice restriction under Section 18(2)
• Use of FIFO method where invoice-wise identification is not feasible
• Treatment of debit and credit notes
• Computation of ITC on capital goods, including mandatory 5% reduction per quarter under Rule 40
• Ensuring that GST component is not claimed as depreciation under the Income-tax Act

Special emphasis is placed on reconciliation with supplier filings such as GSTR-1, GSTR-1A and GSTR-4, reducing the risk of mismatches and future litigation.

Refund and Post-Supply Certification Provisions

Beyond Section 18, the handbook also covers certifications under Section 54 of the CGST Act, including:

• Certification for non-passing of tax incidence in refund claims
• Certification for additional foreign exchange remittance due to upward price revision

Further, it incorporates recent departmental clarifications through Circular No. 183/15/2022-GST and Circular No. 212/6/2024-GST, dealing with issues such as wrong classification, incorrect GSTR-3B reporting, and ITC reversal on post-supply discounts.

Standardised Formats and Practitioner Checklists

One of the standout features of the handbook is the inclusion of suggested certificate formats, annexure templates, and column-wise explanations, making it a ready-to-use reference for practitioners. Comprehensive checklists for Cost Accountants help ensure compliance with statutory conditions, documentation standards, and professional safeguards such as management representation letters and limitation-of-use clauses.

Strengthening Professional Credibility in GST

By consolidating legal provisions, procedural rules, certification formats, and professional guidance in one publication, the ICMAI handbook seeks to standardise GST certification practices and enhance the credibility of CMA-issued certificates before tax authorities.

The handbook reinforces that GST certifications are not mere compliance documents but play a crucial role in protecting revenue, facilitating legitimate ITC claims, and ensuring seamless transitions within the GST framework. For CMAs, it underscores their expanding role as assurance providers and value-added advisors in India’s indirect tax regime.

Read More: New Compliance Architecture for ITC Governance: ICMAI Handbook on Invoice Management System Under GST [DOWNLOAD NOW]