Matching & Reconciliation under GST – Importance & Procedure

GST Reconciliation and Matching are not new to any taxpayer. This has been prevalent in earlier VAT and excise regime too. Then, the matching of data between the books of accounts and tax returns was an easy task for many business organisations. If the tax department on processing returns found some discrepancy, communications would be sent to the taxpayer and accordingly further scrutiny and audits would be carried out by the authorities.

But under GST, this process has gained significance as the sanity of the Input tax credit utilised by businesses is monitored by the GST authorities regularly. Also, the taxpayers must on regular basis reconcile their data every month with the data declared by its vendors too. The return filing and processing are semantically automated and the GST returns are inter-linked.

1. What is Matching & Reconciliation under GST?

Following Mismatches can be noticed by taking up following Matching and Reconciliation exercises:

• Differences between the amount of credit shown in GSTR- 3B and the GSTR 2A or/and
• Discrepancies between GSTR-3B and GSTR-1 or/and
• Differences in the provisional credit claimed and actual credit that is claimable. This situation arises usually during transition stages.

Any differences noticed between these returns will lead to scrutiny notices being issued to the taxpayers.

There can be several causes for mismatches. Popular ones are:

1. The vendor has declared liability but credit is not availed in GST returns: Such credits should be availed at the earlier of due date of September returns or Annual returns.
2. The vendor has not declared liability on supplies made but businesses have availed credit on such procurements in the GST returns: Businesses should follow up with the vendor to ensure that the liability is declared. Else, risks of such credits being disallowed may arise.
3. Mismatch between liability declared by the vendor and credit availed: The reasons for differences should be identified and reconciled appropriately (e.g. by issuing debit notes/credit notes etc) before 30 September, 2018.
4. Mistakes in the details furnished: There can be mismatch in the fields such as GSTIN of the supplier/recipient, number and date of the invoice/debit note etc. Make amendments in the GST returns of the month following the relevant month when mistakes were committed.

Reconciliation under GST although seems to be a simple process due to automation but still consumes lot of time and resources, as taxpayers are required to continuously communicate with vendors for making amendments in the returns filed by them or even to track. It would not tasking for businesses having a handful of transactions to monitor. However, in case you have thousands of invoices in a month, then even a single digit percentile will be a significant volume. Therefore, one must reconcile the returns data on regular basis under GST.

2. Why is GST Reconciliation required?

There are several reasons why reconciliation for GST returns data is required by businesses under GST.

1. As per the new proposed model of GST returns by GSTN, taxpayers will be able to claim ITC only if the invoice is present as a part of their 2A data or vendor data. Owing to this, taxpayers will now need to do a reconciliation wherever the ITC as per their purchase register and 2A data is not matching.

2. GST returns are filed monthly or quarterly basis. Finally, after the financial year gets over, annual returns must be filed before the 31st December of subsequent FY. This would need consolidation of the data reported over the FY. In order to ensure the correctness of the declaration made and to avoid duplications, taxpayer must reconcile the data, then consolidate the values and make the declaration.

3. Certain deadlines are stipulated in the GST laws for making amendments to GST returns data or to claim ITC. As per CGST Act, following actions must be taken at the earlier of due date of the September ,2018 GST returns or Annual returns:

• Claim eligible ITC against any invoice raised in FY 2017-18.
• Any apportionment of ITC belonging to FY 2017-18, as eligible and ineligible not made earlier must be affected before the deadline.
• Declare CDNs issued against any Invoices raised in FY 2017-18.
• File Amendments to information reported in the GST Returns filed between July 2017 to March 2018.
• Taxpayers who opted into Composition scheme or the vice versa current year 2018-19, may make amendments to the information reported in the GST returns filed in FY 2017-18 prior to conversion.

3. How to do GST Reconciliation?

To start with, Reconciliation must be done within the GSTIN and then must be taken to the PAN level. Reconciliation must be done across months for the entire FY 2017-18. Not just that, but the amendments made to GST returns of FY 2017-18 in the CY 2018-19 must also be considered.

Input tax credit (ITC) is the most important component of your GST returns as it holds greater relevance when compared to any other component of the GST returns. The stage at which the sanctity of claims were checked in the previous tax regime is no longer the same as the current GST regime. The genuineness can be confirmed by a taxpayer now at a stage of filing GST returns( vis-vis with GSTR-2A & take action). Earlier, tax authorities usually carry out this check while processing the returns.

Hence, the vendor-wise reconciliation must be done on a regular basis. If not done, taxpayer must consider doing it before filing September 2018 GST returns. This will help identify and declare any unclaimed ITC within the deadline.

• Reconcile transitional ITC
• Claim ITC belonging to FY 2017-18, if not claimed earlier or reverse the ineligible ITC, if not identified and done earlier.
• Match Table of exports at 6A of GSTR-1 vis-a-vis Corresponding declaration in GSTR-3B
• Matching Table of exports at 6A of GSTR-1 vis-a-vis details of shipping bills submitted on ICEGATE
• Comparison between Annual Income Tax Return with Annual GST return

Declaration of Turnover from Business(at PAN level)

• Comparing Purchase register vis-a-vis GSTR-2A for the entire year 2017-18
• Compare GSTR-1 vis-a-vis GSTR-3B
• To Compare the ITC in GSTR-3B vis-a-vis GSTR 2A  for the entire year 2017-18

4. What are the major issues with Reconciliation?

The primary concerns of the taxpayer revolve around the following:

Am I:

• Being Tax compliant in accordance with GST and it’s claiming of ITC?
• At fault anywhere and hence the possibility of getting notices later?
• Missing out on possible working capital by claiming lesser than what I should be claiming?
• Who are the suppliers from whom I am getting the most amount of pain reconciling and how to make it easier for them and for myself?

The major issues with the Reconciliation under GST between GST returns are:

• The invoice number that the purchaser has recorded does not match with seller’s invoice received in 2A. Both follow a different convention.
• The purchaser may work in multiple states, and the seller has raised invoice with another GSTIN/HQ GSTIN instead of the actual purchaser GSTIN. In this case it might not reflect completely at a GSTIN level.
• The invoice date by purchaser doesn’t match with seller. Difference because of date of recording the invoices is different at both places. Mostly purchaser at fault here as they should’ve entered the same date as in Sales invoice.
• The purchaser and supplier have recorded invoices in different return periods.
• Invoice value from Supplier and Purchaser differs by a minor value because both parties have different conventions of rounding off.
• The invoice value differs at supplier and purchaser’s end in case a CN/DN is issued and it fails to match in a recon row.
• When invoice number and date do not match while only the invoice value matches between two parties.
• There are multiple invoices between a purchaser and supplier where every invoice is of same value at different dates and one of the parties has recorded invoices higher than the other. This happens in case of regular fixed supply business.

One of major challenges in doing a reconciliation is that both parties involved may have different nomenclature of storing the invoice numbers, while the implementation has a hard match around invoice number.

5. How to choose a tool or software to reconcile faster and ensure 100% compliance?

A technological solution which can solve for all of the major pain points discussed above. This will add a lot of value to the business owner.

Certain features that one must find in a powerful reconciliation tool or system for matching and reconciling GST returns data are:

• The tool should be able to handle a massive amount of data.
• It should make it easy for the business owner to get data into the system for reconciliation and also take it back to his ERP post- GST reconciliation. A seamless integration here would help. It should be able to get the data into the reconciliation system from any kind of source – ERP, Excel, bill books, etc.,
• It should be able to provide deep reporting and insights which can help answer the pain points above.
• Overall, it should also make the whole process month over month seamless and largely efficient that the business owner does not feel a burden.
• It should allow for easy data sharing and collaboration between the business owner and his accountant(s).
• Given the Government GST rules might keep changing over time, the system should have the ability to evolve fast and in-line with Govt. changes. This will abstract the real problem away from the business owner and make it still seamless for them.
• It must be extremely intelligent to handle any case of missing/wrong information. It can be wrong dates, wrong invoice numbers, missing items, wrong tax rate, wrong sale value and a lot more. The system should be able to provide the most effective reconciliation in all such scenarios.
• The system should be real-time and proactive. A seamless integration to bring the invoice for reconciliation and real-time automatic application of pre-defined rules will help.
• Proactive reminders and automatics to reduce human intervention will also make the system more efficient.

ClearTax GST offers the most powerful and Advanced Reconciliation Tool that comes packed with all the above discussed features and intelligence to auto-identify, match entries and assures 100% ITC claimed. Some of its tools are:

• GSTR-3B vs GSTR-1 Tax Comparison Report

Compares GSTR-3B and GSTR-1. Gives a graphical representation as well. This enables clients to understand the difference in the tax liability which helps clients avoiding penalty or Notice from GSTN

• GSTR-3B vs GSTR-2A ITC Comparison Report :

Compares GSTR-3B and GSTR-2A. Gives a graphical representation as well. If ITC is claimed in excess, this can be identified here for each month. Thus ensuring that the clients are prepared for any notice that comes their way

• Monthly Tax and ITC summary Report :

Month on Month view for the top management on the tax paid and ITC taken by each of the GSTINs.

• Advanced Reconciliation Tool :

1. Download multi-month GSTR-2A in a click – Enabling all clients to start reconciliation of their 2A and purchases by pulling complete financial year’s 2A report.
2. Intelligent and Smart Rules – ClearTax Recon uses intelligent and smart rules for you to get suggestions on what could be reconciled without taking much effort in looking for. Helps you do recon faster and easier.
3. Claim Max ITC – Use ClearTax to claim 100% ITC.
4. Four buckets in ClearTax GST to identify data match, mismatch type :

• Matched

Shows in this section when purchase invoices uploaded by you and GSTR-2A data downloaded from the GSTN portal matches based on default and suggestions from ClearTax

• Mismatch In Values

Shows in this section when purchase invoices uploaded by you and GSTR-2A data downloaded from the GSTN portal doesn’t match which is highlighted in red on the software

• Missing In My Data

Shows in this section when you have not uploaded purchase invoices but data is present on 2A side

• Missing In Supplier Data (Not In 2A) My Data

Shows in this section when you have uploaded purchase invoices but data is not present on 2A side