GST getting stricter again : Now, ITC will be restricted to 20% if not matching with 2A


GST getting stricter again : Now, ITC will be restricted to 20% if not matching with 2A

Not indication No. 49-2019- Central Tax – Amend Rules

Notification No. 49/2019 has made some critical changes in the CGST Rules which will have far reaching impact.
First and foremost, now ITC in respect of invoices & debit notes which is not  uploaded by the suppliers in their GSTR-1 shall not be available fully but shall be restricted to 20%.
It means that eligible credit available in respect of invoices or debit notes the details of which have been uploaded by the suppliers in GSTR-1 will not be available fully till it is uploaded by the supplier.
Now, after this amendment, regular matching of ITC with the details available in GSTR-2A will become necessary. Follow-up with non-compliant suppliers to be done on a regular basis now.
Second amendment is done in Rule 61(5) with retrospective effect from 01-07-2017* by making GSTR-3B as the return specified under Section 39, wherever the time limit for filing GSTR-1 or GSTR-2 has been extended.
Impact and purpose is to makethe judgement & observation of the Gujarat High Court in the case of AAP and Company in non-operational.


  1. To my understanding now ITC, in respect of yet to be uploaded invoices, can also be claimed upto a maximum of 20% of the otherwise available credit as per GSTR-2A (uploaded invoices by all suppliers) for that period e.g. in case if Y, as per GSTR-2A, is entitled to credit of input tax amounting to Rs.1000/-, he can claim ITC upto a maximum of Rs.200/- against non-uploaded but otherwise eligible invoices/debit notes. Thus if invoices showing GST for Rs.150/- have not been uploaded, Y can claim whole of such ITC, being within the limit of 20% of available credit in GSTR-2A.

    Kindly correct me if I am wrong. Of course, it will result in more and more reconciliations.


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