Revised timeline for taking Input Tax Credit pertaining to Financial Year 2017-18
This is to apprise you regarding the revised timeline for availment of Input Tax Credit (‘ITC’) of invoices of Financial Year (‘FY’) 2017-18 and debit notes pertaining to invoices of FY 2017-18.
In our update dated November 26, 2018, we discussed last date for availing ITC for FY 2017-18 is due- date of filing of annual return i.e. December 31, 2018. In the same update, we also discussed that Section 16(4) of the Central Goods and Services Tax Act, 2017 (‘CGST Act’) stipulates that ITC can be availed by earliest of the following dates:
- Due date of furnishing of return under Section 39 for September of following financial year, or
- Date of furnishing of annual return
We highlighted that since GSTR-3B is not a return under Section 39, date of filing of annual return shall be the last date of availing ITC.
Notably, the proviso inserted to Section 16(4) of the CGST Act also mention ‘return’ under Section 39 for March 2019 as last date for availing ITC. Therefore, as GSTR-3 is not in vogue, the date for furnishing annual return for FY 2017-18 (June 30, 2019) is relevant to determine timeline for ITC availment.
In case a taxpayer has missed availing ITC of FY 2017-18, they can avail such credit by date of filing of annual return. This will be the last opportunity for taxpayers to avail any missed ITC.