This circular provides guidance on how to deal with mismatches between ITC claimed in GSTR-3B and that appearing in GSTR-2A for the period 1 April 2019 to 31 December 2021. It explains that for 1 April 2019 to 8 October 2019, the same process clarified in Circular 183/15/2022 applies. From 9 October 2019 onward, rule 36(4) allowed additional ITC beyond GSTR-2A but only within specified limits: 20% (09.10.2019–31.12.2019), 10% (2020) and 5% (2021). ITC beyond these limits is inadmissible even if suppliers’ tax payment certificates are furnished. The circular includes illustrations and clarifies how cumulative adjustments for certain months (as permitted by notifications) should be applied.

It also reiterates that from 1 January 2022, ITC is allowed only when invoices are reported by suppliers and reflected in GSTR-2B. These instructions apply only to ongoing scrutiny, audit or investigation for the specified period, including cases pending adjudication or appeal.