• Cygnet IRP
  • Glib.ai
  • IFSCA
Cygnet.One
  • About
  • Products
  • Solutions
  • Services
  • Partners
  • Resources
Generic selectors
Exact matches only
Search in title
Search in content
Post Type Selectors
Get Started
About
  • Overview

    A promise of limitless possibilities

  • We are Cygnet

    Together, we cultivate an environment of collaboration

  • In the News

    Catch up on the latest news and updates from Cygnet

  • CSR

    Impacting Communities, Enriching Lives

  • Careers

    Join Our Dynamic Team: Careers at Cygnet

  • Contact Us

    Connect with our teams across the globe

What’s new

chatgpt

ChatGPT: Raising the Standards of Conversational AI in Finance and Healthcare Space

Full Story

Products
  • Cygnet Tax
    • Indirect Tax Compliance
      • GST Compliance India
      • VAT Compliance EU
      • VAT Compliance ME
    • e-Invoicing / Real time reporting
    • e-Way Bills / Road permits
    • Direct Tax Compliance
    • Managed Services
  • Cygnet Vendor Postbox
  • Cygnet Finalyze
    • Bank Statement Analysis
    • Financial Statement Analysis
    • GST Business Intelligence Report
    • GST Return Compliance Score
    • ITR Analysis
    • Invoice Verification for Trade Finance
    • Account Aggregator – Technology Service Provider (AA-TSP)
  • Cygnet BridgeFlow
  • Cygnet Bills
  • Cygnet IRP
  • Cygnature
  • TestingWhiz
  • AutomationWhiz
Solutions
  • Accounts Payable
  • GL Reconciliation
  • BridgeCash
  • Litigation Management
  • Intelligent Document Processing

What’s new

financial reporting

The Critical Role of Purchase Invoices in Financial Reporting

Full Story

oil gas industry

Achieved efficient indirect tax reconciliation for an oil and gas giant

Full Story

Services
  • Digital Engineering
    • Technical Due Diligence
    • Product Engineering
    • Application Modernization
    • Enterprise Integration
    • Hyperautomation
  • Quality Engineering
    • Test Consulting & Maturity Assessment
    • Business Assurance Testing
    • Enterprise Application & Software Testing
    • Data Transformation Testing
  • Cloud Engineering
    • Cloud Strategy and Design
    • Cloud Migration and Modernization
    • Cloud Native Development
    • Cloud Operations and Optimization
    • Cloud for AI First
  • Data Analytics & AI
    • Data Engineering and Management
    • Data Migration and Modernization
    • Insights Driven Business Transformation
    • Business Analytics and Embedded AI
  • Managed IT Services
    • IT Strategy and Consulting
    • Application Managed Services
    • Infrastructure Managed Services
    • Cybersecurity
    • Governance, Risk Management & Compliance
Partners
Resources
  • Blogs
  • Case Studies
  • eBooks
  • Events
  • Webinars

Blogs

AI in Business Intelligence: Key Benefits and Use Cases

AI in Business Intelligence: Key Benefits and Use Cases

View All

Case Studies

From Manual Mayhem to Seamless Control: A 90% Leap in Efficiency

From Manual Mayhem to Seamless Control: A 90% Leap in Efficiency

View All

eBooks

Build Smart Workflow with Intelligent Automation and Analytics

Build Smart Workflow with Intelligent Automation and Analytics

View All

Events

37th Edition India CFO SUMMIT 2025

37th Edition India CFO SUMMIT 2025

View All

Webinars

Code is the New Data Now! Have you onboarded your digital colleague yet?

Code is the New Data Now! Have you onboarded your digital colleague yet?

View All
Cygnet IRP
Glib.ai
IFSCA

Handle Notices for ITC Mismatch in GSTR-2A and GSTR-3B for FY 2017-18 and 18-19

  • By Komal Vithalani
  • December 8, 2023
  • 4 minutes read
Share
Subscribe

Introduction

In the complex taxation landscape, businesses often navigate the intricacies of notices issued by the GST Authority. These formal notices from GST authorities require proper attention and strategic handling to address concerns related to discrepancies, mismatches in various forms and returns filed, or any other non-compliance with the law.

Recognizing the need for clear guidelines and consistent communication, the GST authorities periodically release circulars to provide essential clarifications. These circulars serve as beacons of understanding, offering insights and directives on how businesses should navigate the intricacies of responding to official notices.

One such circular, No. 183/15/2022-GST, was issued on 27th December 2022 to provide clarification on how to deal with notices related to mismatch in ITC in FORM GSTR-3B as compared to FORM GSTR-2A for FY 2017-18 and FY 2018-19.

Since the scrutiny/audit/investigation for the said years has increased and has been growing so far, the need to understand this circular has become vital for businesses before providing a reply to such notices.

This blog will delve into the explanations, clarifications, and simple understanding of what this circular states and how the business will be able to deal with such notices.

Let’s overview the scenarios that can cause a mismatch in GSTR-2A and GSTR-3B.

Scenarios for Mismatch resulting in the issuance of Notice.

  • When the supplier failed to file GSTR-1 for the said tax period but filed GSTR-3B, which resulted in the non-reflection of supplies in GSTR-2A of the recipient for the said tax period.
  • When the supplier filed GSTR-1 and GSTR-3B but failed to report a particular transaction in GSTR-1, which resulted in the non-reflection of that transaction in GSTR-2A of the recipient for the said tax period.
  • When the supplier has issued an invoice as per Rule 46 of CGST Rules, 2017 for the supplies made to a registered person, but the said transaction was reported as a B2C transaction instead of a B2B transaction in GSRT-1, which resulted in the non-reflection of said transaction in GSTR-2A of the recipient for the said tax period.
  • When the supplier has filed both GSTR-1 and GSTR-3B, but the incorrect GSTN of the recipient has been reported in GSTR-1, which resulted in the non-reflection of that transaction in GSTR-2A of the recipient for the said tax period.

Now that we know the scenarios that can be responsible for the mismatch in GSTR-2A and GSTR-3B, we shall understand the clarification given by the GST council to tackle such notices.

The GST Authority may look into compliance with Section 16 of the CGST Act, 2017, regarding fulfillment of the conditions for the availment of ITC. Let’s have a look at the conditions.

Section 16- Conditions for availment of ITC.

  1. That he is in possession of a tax invoice or debit note issued by the supplier or such other tax-paying documents.
  2. that he has received the goods or services or both
  3. that he has paid the amount towards the value of supply, along with tax payable thereon, to the supplier.
  4. he has furnished the return under section 39.

ITC can be availed on fulfillment of the above conditions, irrespective of the fact that the transaction was not reflected in GSTR-2A of the recipient. The following requirements must be fulfilled to prove the 3rd condition, i.e., the supplier has discharged his tax liability towards the value of ITC availed.

  • When the difference in ITC claimed in GSTR-3B compared to GSTR-2A is more than 5 lakh rupees.

The registered person has to produce a certificate for the concerned supplier from CA (Chartered Accountant) or CMA (Cost Accountant) to the proper officer, certifying that supplies in respect of invoices not reflected in GSTR-2A have been made to the recipient and the tax has been paid by the supplier in his return in GSTR-3B.

Certificates issued by CA or CMA shall contain UDIN. UDIN of the certificate issued by CAs can be verified from the ICAI website, and that issued by CMAs can be verified from the ICMAI website.  

  • When the difference in ITC claimed in GSTR-3B compared to GSTR-2A is up to 5 lakh rupees.

The registered person, also known as the claimant, has to produce a certificate from the supplier to the proper officer that supplies in respect of invoices not reflected in GSTR-2A have been made to the recipient and the tax has been paid by the supplier in his return in GSTR-3B.

Other points to be considered for claiming mismatched ITC.

  • Section 16(4) specifies the time limit within which ITC must be claimed in GSTR-3B, and after that, ITC cannot be claimed. But as per Order No. 02/2018 – CT dated 31.12.2018, Input tax credit for financial year 2017-18 can be claimed till the due date of furnishing of the return for the month of March 2019.
  • This clarification is for the bonafide or genuine errors committed in reporting during the said years, and the guidelines are clarificatory. They may be applied as per the facts of the cases.  It will not be considered an interpretation of the law or overriding the law.
  • This clarification and instructions are for ongoing scrutiny/audit/investigation proceedings for FY 2017-18 or 2018-19 and not for 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.

Conclusion

In conclusion, addressing the notice of mismatch between the GST returns in Form GSTR-2A and GSTR-3B is imperative for maintaining compliance and fostering a transparent business environment. Timely clarifications by the government for disparities and rectification of such disparities/mismatches by businesses are crucial to avoid potential complications with tax authorities. This process ensures accuracy in tax reporting and demonstrates a commitment to adherence to regulatory requirements.

Businesses must proactively resolve discrepancies, foster a culture of compliance, and reinforce their commitment to ethical and lawful business practices. By taking swift action to rectify the differences, companies can contribute to a smooth and efficient GST ecosystem, safeguarding their financial standing and maintaining the trust of stakeholders.

Author
Komal Vithalani Linkedin
Komal Vithalani
Content Writer

Komal Vithalani, a Chartered Accountant and Commerce graduate, is a dedicated professional committed to delivering value with years of expertise in navigating the complexities of indirect tax laws. Her practical excellence includes managing perplexed litigations, dispensing tactical tax advice, conducting thorough compliance checks, supervising audits, and crafting articulate and insightful content. At Cygnet, Komal seamlessly blends her profound understanding of tax regulations with cutting-edge tax technology. Leveraging her competence, she adeptly transforms complex tax tech jargon into concise, impactful, and engaging content. This not only aids readers in comprehending tax-related topics with enlightening clarity but also ensures the delivery of narratives that resonate broadly.

Related Blog Posts

TDS: New Provisions On The Corner
TDS: New Provisions On The Corner

CalendarMay 11, 2021

Mastering GST Compliance in 2025: Best Practices for Indian Enterprises 
Mastering GST Compliance in 2025: Best Practices for Indian Enterprises 

CalendarJuly 09, 2025

Understanding Electronic Credit Reversal and Re-claimed Statement (ECRS)
Understanding Electronic Credit Reversal and Re-claimed Statement (ECRS)

CalendarSeptember 18, 2023

Sign up to our Newsletter

    Latest Blog Posts

    Accelerating Digital Lending: How Automated Onboarding Enhances Vendor and Customer Journeys
    Accelerating Digital Lending: How Automated Onboarding Enhances Vendor and Customer Journeys

    CalendarJuly 31, 2025

    Navigating IMS, ISD & GST Amendments: Top FAQs Answered by Experts
    Navigating IMS, ISD & GST Amendments: Top FAQs Answered by Experts

    CalendarJuly 31, 2025

    AI-Powered Indirect Tax Compliance: From Reactive to Proactive 
    AI-Powered Indirect Tax Compliance: From Reactive to Proactive 

    CalendarJuly 29, 2025

    Let’s level up your Business Together!

    The more you engage, the better you will realize our role in the digital transformation journey of your business








      I agree to the Terms & Conditions and Privacy Policy and allow Cygnet.One (and its group entities) to contact me via WhatsApp / Email / SMS / Phone Call.*

      I agree to receive occasional product updates and promotional messages from Cygnet.One (and its group entities) on WhatsApp / Email / SMS / Phone Call.

      Cygnet.One Locations

      India

      Cygnet Infotech Pvt. Ltd.
      2nd Floor, The Textile Association of India,
      Dinesh Hall, Ashram Rd,
      Navrangpura, Ahmedabad, Gujarat 380009

      Cygnet Infotech Pvt. Ltd.
      Community Coworking Space,
      501 B-Wing Ackruti Trade Center Road Number 7,
      Midc, Marol, Andheri East, Mumbai 400093

      Cygnet Infotech Pvt. Ltd.
      WESTPORT, Urbanworks,
      5th floor, Pan Card Club rd.,
      Baner, Pune, Maharashtra 411045

      Cygnet Infotech Pvt. Ltd.
      10th floor, 73 East Avenue,
      Sarabhai campus, Vadodara, 391101

      Global

      CYGNET INFOTECH LLC
      125 Village Blvd, 3rd Floor,
      Suite 315, Princeton Forrestal Village,
      Princeton, New Jersey- 08540

      CYGNET FINTECH SOFTWARE
      Office No 3301-022, 33rd Floor,
      Prime Business Centre,
      Business Bay- Dubai

      CYGNET INFOTECH PRIVATE LIMITED
      Level 35 Tower One,
      Barangaroo, Sydney, NSW 2000

      CYGNET ONE SDN.BHD.
      Unit F31, Block F, Third Floor Cbd Perdana 3,
      Jalan Perdana, Cyber 12 63000 Cyberjaya Selangor, Malaysia

      CYGNET INFOTECH LIMITED
      C/O Sawhney Consulting, Harrow Business Centre,
      429-433 Pinner Road, Harrow, England, HA1 4HN

      CYGNET INFOTECH PTY LTD
      152, Willowbridge Centre,
      39 Cronje Drive, Tyger Valley,
      Cape Town 7530

      CYGNET INFOTECH BV
      Peutiesesteenweg 74, Machelen (Brab.), Belgium

      Cygnet One Pte. Ltd.
      160 Robinson Road,
      #26-03, SBF Centre,
      Singapore – 068914

      • Explore more about us

      • Download Corporate Deck
      • Terms of Use
      • Privacy Policy
      • Contact Us
      © Copyright – 2025 Cygnet.One
      We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume that you are happy with it.
      Fill in the form to download

      Error: Contact form not found.

      Cygnet.One AI Assistant

      ✕
      AI Assistant at your help. Cygnet AI Assistant