Short summary: Since the amendments introduced by the Finance Act, 2021 (effective 1 January 2022), taxpayers should reconcile Input Tax Credit (ITC) with GSTR-2B before claiming in GSTR-3B. In 2025, with Invoice Management System (IMS) and stricter enforcement, this reconciliation is mandatory for safe filing.
Legal background — what changed and when?
The legal change came through the Finance Act, 2021: insertion of Section 16(2)(aa) and consequential amendment to Rule 36(4) of the CGST Rules. Practically, the amendment has been effective from 1 January 2022. In short: a recipient must ensure supplier details are furnished in GSTR-1 and appear in the recipient’s GSTR-2B to claim ITC for that period.
What is GSTR-2B and when is it generated?
GSTR-2B is an auto-generated static ITC statement published by the GST portal. It is normally generated on the 14th of the succeeding month (for example, invoices for July reflect in the GSTR-2B published on 14th August). Important: For quarterly filers, the relevant GSTR-2B is generated on the 14th of the month after the quarter ends (e.g., Apr–Jun quarter → GSTR-2B on 14th July).
Why is invoice-level matching necessary?
- Only invoices reflected in GSTR-2B are considered eligible for ITC in that period.
- If an invoice is in your books but not in GSTR-2B, it is treated as blocked ITC until the supplier files/accepts it.
- Claiming ineligible ITC can trigger notices, interest and penalties; reversal is required if claim was made incorrectly.
IMS (Invoice Management System) — new control
IMS allows suppliers to mark invoices as Accepted / Rejected / Pending. Only accepted invoices flow into GSTR-2B. Buyers must therefore monitor IMS status and coordinate with suppliers to ensure invoices are accepted or re-filed in time.
Step-by-step practical workflow (recommended)
- On/after the 14th (or portal-announced date), download GSTR-2B for your GSTIN.
- Prepare your Books ITC sheet (invoice#, supplier GSTIN, invoice date, tax value).
- Perform invoice-level reconciliation: invoice number, date and tax value match.
- Mark Matched / Mismatch / Missing. For mismatches, open IMS and check status.
- Contact supplier to accept or revise the invoice. Keep proof (email/WhatsApp) for audit.
- Only include matched ITC in GSTR-3B; if you mistakenly included ineligible ITC, reverse it in the next GSTR-3B (Table 4(B)).
How our Excel Utility helps
Manual reconciliation is slow and error-prone. Our GSTR-2B Excel Utility automates invoice-level matching, flags mismatches, exports reports, and helps plan reversals — saving time and reducing compliance risk.
Mistakenly claimed ITC — reversal & reporting
If you claimed ITC that was not eligible (i.e., not in GSTR-2B), reverse it in the subsequent GSTR-3B filing as required (report in Table 4(B)) and retain reconciliation records. Interest/penalty may apply if reversal and payment obligations are not followed timely.
Conclusion
Since 1 January 2022, the legal framework has made GSTR-2B matching fundamental to ITC eligibility. For quarterly filers note the quarter-end timing (GSTR-2B on 14th of the month after quarter). Adopt a monthly/periodic reconciliation process, use automation where possible, and consult your tax professional before final filing.
⚠️ Disclaimer: This article is for educational and informational purposes only. It does not constitute professional tax advice. Consult a qualified tax advisor for advice specific to your circumstances.
References
- Finance Act, 2021 — amendments (Section 16(2)(aa)) — effective 01-Jan-2022.
- CGST Rule 36(4) — amendment and implementation details.
- GSTN advisories — GSTR-2B generation & IMS guidance.