ITC Reconciliation — GSTR-2A vs GSTR-2B

Learning Objectives

• Distinguish between GSTR-2A (dynamic) and GSTR-2B (static) and use each correctly
• Build a monthly reconciliation in Excel between Purchase Register, 2A, 2B
• Apply Rule 36(4) — the current 100% match rule and its history
• Handle four common scenarios: vendor not filed, wrong tax, wrong GSTIN, duplicate invoice
• Draft a vendor communication letter that actually gets ITC reflected
• Know the operational tweaks for QRMP and IFF filers

GSTR-2A vs GSTR-2B — The Single Most Important Distinction

The single rule to remember:

2A is for tracking. 2B is for filing.

A taxpayer who claims ITC by looking at 2A instead of 2B will routinely over-claim — because 2A is still picking up late-filed invoices that 2B has already excluded.

Rule 36(4) — The Journey to 100% Match

Rule 36(4) is the legal anchor for ITC reconciliation. Its threshold has tightened over five years:

Current law (FY 25-26):

You can claim only the ITC that appears in your GSTR-2B for that month. No provisional claim. No "trust the vendor and reverse later."

The only exception is Section 16(2)(c) compliant invoices where the supplier has paid the tax — but proving this without 2B visibility is operationally impossible.

The Monthly Reconciliation Workflow

Every month, around the 16th–20th, the GST team performs this five-step reconciliation:

Step 1 — Pull the Three Data Sources

1. Purchase Register (PR) — from accounting software (Tally, SAP, Zoho) — every purchase invoice recorded in the month
2. GSTR-2B JSON — downloaded from GST portal → Returns → GSTR-2B → Download
3. GSTR-2A JSON — same path, used for tracking history

Step 2 — Load Into an Excel Reconciliation Sheet

Standard column layout:

| Sl | Supplier GSTIN | Supplier Name | Invoice No | Invoice Date | Taxable Value | IGST | CGST | SGST | Total Tax | Source |

Source column has three values: PR only, 2B only, Both — match.

Step 3 — Match on Key

The matching key is: Supplier GSTIN + Invoice Number + Invoice Date

Use Excel's INDEX-MATCH or VLOOKUP, or Power Query for larger datasets.

Step 4 — Categorise the Output

Every row falls into one of these categories:

Step 5 — Take Action on Each Bucket

Sunrise Retail — April 2025 Reconciliation

💼 Sunrise Retail Pvt Ltd

Sneha pulled the data on 16 May 2025. Here is what she found.

The Numbers

Purchase Register — April 2025:

GSTR-2B — April 2025 (frozen on 14 May):

The Gap

ITC in books: ₹7,16,400 — ITC in 2B: ₹3,02,400 — Gap: ₹4,14,000

The missing invoice: TechWorld Mumbai TW-2025-208 dated 18-Apr-2025 for ₹4,14,000 IGST. TechWorld is a QRMP filer and the invoice fell outside their April IFF cut-off — they will file it in their July GSTR-1 (quarterly).

Sneha's Action

1. Claim only ₹3,02,400 ITC in April GSTR-3B (the matched amount).
2. Defer ₹4,14,000 — record in a "deferred ITC tracker" with the expected month of recovery (likely July 2025 2B).
3. Send a polite reminder to TechWorld's accounts contact — confirming the invoice will be reported in their July GSTR-1.
4. Cross-check in July's 2B — if it appears, claim there.
5. Escalate if it doesn't appear by November 2026 (time-bar = 30 Nov of FY following the FY of invoice). Below that, ITC is permanently lost.

Vendor Non-Filing — The Four Scenarios

When a vendor's invoice doesn't appear in your 2B, there are four root causes:

Scenario 1 — Vendor Hasn't Filed GSTR-1 / IFF Yet

Most common. The vendor is a QRMP filer and the invoice fell after their IFF cut-off, or they simply missed the filing date.

Action: Wait one or two months. Track in deferred ITC tracker. Send polite reminder.

Scenario 2 — Vendor Filed but Wrong GSTIN

Vendor entered an incorrect GSTIN in their GSTR-1 — yours starts with 36, they typed 38. The invoice goes to some other taxpayer's 2A — not yours.

Action: Send formal communication letter requesting an amendment in next GSTR-1.

Scenario 3 — Vendor Filed with Wrong Invoice Number or Date

Auto-matching by GSTIN + Invoice Number + Date fails. The invoice exists in 2B but doesn't link to your PR row.

Action: Manual review — flag for visual matching by supplier name + value. Request vendor amendment if discrepancy is real.

Scenario 4 — Vendor Has Stopped Filing (Defaulter)

Vendor's GSTIN status on the portal shows "Suspended" or "Cancelled with retrospective effect." Bigger problem — invoices from such suppliers are treated as ineligible ITC under Section 16(2)(c).

Action: Reverse ITC if claimed; flag the relationship for review; consider holding outstanding payments until issue resolves.

The Vendor Communication Letter

A well-written letter does three things — it reminds, it documents (for audit defence), and it shifts the relationship from "vendor is forgetting" to "we are formally tracking this." Keep it short.

Template:

[On Sunrise Retail letterhead — 17 May 2025]

To: TechWorld Mumbai
Attn: Accounts/Compliance — Mr. Rajesh Patel
GSTIN: 27AAACT5678B1ZX

Sub: Pending GSTR-1 reporting of invoice TW-2025-208 dated 18 Apr 2025
     — ITC visibility for Sunrise Retail Pvt Ltd (GSTIN 36AACCS1234A1ZP)

Dear Sir,

This is in respect of the following invoice raised by your good office:

  Invoice No: TW-2025-208
  Invoice Date: 18 April 2025
  Taxable Value: ₹23,00,000
  IGST @ 18%: ₹4,14,000
  Total: ₹27,14,000

We have recorded this purchase in our books for April 2025. However, this
invoice has not appeared in our GSTR-2B for April 2025. As a result, we
are unable to claim ITC of ₹4,14,000 in our current month's GSTR-3B.

We request you to:

  1. Confirm whether this invoice is included in your GSTR-1 / IFF for
     April 2025; if not, the period in which it will be filed.

  2. Verify the recipient GSTIN on your records as 36AACCS1234A1ZP.

  3. Share the GSTR-1 acknowledgment once filed.

We have not yet claimed this ITC in our return. Please treat this as a
priority. Any delay beyond the time limit of 30 November 2026 will result
in permanent loss of ITC for Sunrise Retail.

For any clarification, our accounts contact is Sneha Reddy at
+91 98765 43210 or sneha@sunriseretail.in.

Thank you for your cooperation.

For Sunrise Retail Pvt Ltd

Sneha Reddy
Finance Director
DIN: 09876543

QRMP and IFF — The Operational Wrinkle

A vendor on the QRMP (Quarterly Return Monthly Payment) scheme files GSTR-1 quarterly, but can upload B2B invoices monthly via IFF (Invoice Furnishing Facility).

Consequence for you, the buyer:

Example:

TechWorld Mumbai is on QRMP for Apr–Jun 2025 quarter.

• If TechWorld uses IFF: Their 18 April invoice can appear in your April 2B (if uploaded by 13 May).
• If TechWorld doesn't use IFF: That invoice appears only in your June 2B when TechWorld files quarterly GSTR-1 on 13 July.

If your vendor doesn't use IFF and you have large monthly purchases from them, you systematically defer two months of ITC every quarter. Ask your top vendors to opt for IFF — it's a one-click setting on the portal.

Recovering "Lost" ITC

ITC isn't lost just because it didn't appear in this month's 2B. The time-bar is generous:

ITC for an invoice dated in FY 25-26 can be claimed until 30 November 2026 OR the date of filing annual return GSTR-9 for FY 25-26 — whichever is earlier.

So a purchase invoice from April 2025 can still be claimed any month up to October 2026 — as long as it eventually shows up in 2B in some month.

The practical recovery flow:

1. April 2025 — invoice not in 2B → defer ITC, log in tracker
2. May–Sep 2025 — keep checking each month's 2B for the missing invoice
3. If it appears in (say) August 2B → claim in August GSTR-3B
4. If it doesn't appear by October 2026 — send a final notice to the vendor; after 30 Nov 2026 the ITC is permanently extinguished

Common Mistakes to Avoid

Practice Exercise

Exercise 1: Sunrise Retail's April 2025 PR shows ITC of ₹9,80,000. April 2025 GSTR-2B shows ITC of ₹8,40,000. What ITC can Sunrise Retail claim in April GSTR-3B?

Exercise 2: A vendor's GSTIN status changes to "Suspended" on 5 May 2025. Sunrise Retail had claimed ₹62,000 ITC from this vendor in April 2025 GSTR-3B (filed on 20 May). What should Sunrise Retail do?

Key Terms

Checklist — what you should now be able to do:

• Pull GSTR-2B and Purchase Register, match in Excel on GSTIN + Invoice + Date
• Categorise every row as Match, PR only, 2B only, or Value mismatch
• Draft a vendor communication letter for a missing invoice
• Diagnose why a QRMP vendor's invoice didn't reach your 2B this month
• Calculate the time-bar for recovering ITC on an old invoice