Clarification issued by CBIC on Invoices not appearing in GSTR2A for the years 2017-18 and 2018-19

CBIC has issued clarification explaining the procedure to be followed in case where the invoices are not appearing in the GSTR2A during the period 2017-18 and 2018-19. As per the clarification issued, the following procedure shall be followed:

1. Firstly, the details of all the invoices on which ITC has been availed in the GSTR3B but which are not appearing in GSTR-2A shall be furnished to the department.
2. Further, the fulfilment of the following conditions shall be justified:
   1. Proper tax invoice or debit note is available in respect of such supplies;
   2. Goods or services have been received; and
   3. Payment for such supplies have been made to the supplier for the taxable value and tax.
3. It is also required to be proved that the supplies do not fall under blocked credit given under section 17 or requires reversal under section 18.
4. In order to verify the fulfilment of the condition given under section 16 (2) (c) of the CGST Act, the following document shall be furnished to the department:
   1. In case, where difference between the ITC claimed in FORM GSTR-3B and that available in FORM GSTR 2A in respect of a supplier for the said financial year exceeds Rs 5 lakh, then from such supplier a certificate from a CA/CMA shall be obtained 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. The certificate shall contain the UDIN.
   2. In case, where difference between the ITC claimed in FORM GSTR-3B and that available in FORM GSTR 2A in respect of a supplier for the said financial year is up to Rs 5 lakh, then the certificate shall be obtained from such supplier himself certifying that supplies in respect of the said invoices have actually been made by him to the said registered person and the tax on such supplies has been paid by him in his return in FORM GSTR 3B.

The certificate is required to be collected for each supplier whose invoices are not available in GSTR2A.

The copy of the circular is attached for reference.

Clarification to deal with difference in ITC in FORM GSTR-3B as compared to FORM GSTR-2A