Government has via a Press Release dated 18.10.2018 clarified on the last date for taking input tax credit on invoices or debit notes relating to such invoices pertaining to the period from July 2017 to March 2018. The due date will be as per the time limit specified under section 16(4) of the CGST Act 2017 which is the due date of furnishing of return under Form GSTR-3B for September 2018 or due date of furnishing of relevant Annual Return, whichever is earlier.
For this, the last date for filing of GSTR-3B for the month of September 2018 is 20th October 2018.
It is clarified by the Press Release that furnishing of details of outward supplies in FORM GSTR-1 by the corresponding supplier and facility to view the same in FORM GSTR-2A by the recipient is in the nature of taxpayer facilitation and does not impact the ability of the taxpayer to avail ITC on self-assessment basis as per provisions of section 16 of the Act. The apprehension that ITC can be availed only on the basis of reconciliation between FORM GSTR-2A and FORM GSTR-3B conducted before the due date for filing of return in FORM GSTR-3B for the month of September 2018 is unfounded as the same exercise can be done thereafter also.
However, for the last date of filing Form GSTR-3B for certain taxpayers for certain taxpayers who have been recently migrated from erstwhile tax regime to GST regime, has been extended via Notification No. 47/2018 dated 10.09.2018. For such taxpayers, the extended date of 31st December 2018 or the date of filing of annual return, whichever is earlier will be the last date for availing ITC in relation to invoices issued during the period from July 2017 to March 2018.
