DIFFERENT ASPECTS OF NOTIFICATION NO. 49/2019-CT, DATED 09.10.2019

APPLICABILITY

1. The notification has been published in the official gazette on 09.10.2019
2. It is an alert for taxpayers who have chosen not to file GSTR-9 for F.Y. 2018-19. They have to claim the accurate provisional ITC in Sep, 2019 return.
3. The CBIC could clarify on the applicable return period for this rule to clear the ambiguity in the minds of taxpayers and professionals.

IMPACT

1. A mid-year change in rules is always challenging for taxpayers.
2. Businesses following manual accounting / without ERPs will have difficulty in reconciliation.
3. Businesses now need to manage their accounts payables carefully since their working capital will have a direct impact with this new rule.

ELIGIBLE ITC

1. Going forward, a taxpayer will be able to claim 20% of the eligible ITC.
2. To arrive at the eligible ITC, a taxpayer has to deduct ineligible ITC reported in GSTR-3B from the total available ITC in GSTR-2A.
3. With this new rule concerning availing provisional ITC, it becomes important for businesses to continuously follow-up with their suppliers to upload the missing invoices.

RECONCILIATION

1. All regular taxpayers must take up reconciliation of GSTR-2A with the purchase register more often than before.
2. Any delay in reconciling will leave taxpayers missing out on their due tax credits, thus affecting their working capital cycle.

CONCERNS

1. Working capital will have a direct impact when the 20% rule gets implemented.
2. Buyers will severely disadvantaged if the supplier fails to upload invoices ; hence, dependency on suppliers will increase.
3. Payments will need to be made via cash despite having ITC, when suppliers fail to upload their invoices.