GST Update — Understanding Electronic Credit Reversal & Re-claimed Statement and RCM Liability / ITC Statemen

06.01.26 04:49 AM - Comment(s) - By RB Associates and Tax Matters

(Explained in Simple Layman Terms)

The GST Network (GSTN) has issued an important update regarding the reporting of:

✔ ITC reversal and re-claim
✔ RCM liability and corresponding ITC claim

To avoid clerical mistakes and excess ITC claims, GSTN has introduced two ledgers on the GST portal:

1️⃣ Electronic Credit Reversal & Re-claimed Statement (Reclaim Ledger)
2️⃣ RCM Liability / ITC Statement (RCM Ledger)

These ledgers help taxpayers correctly track ITC reversal, re-claim and RCM-related ITC.

Going forward, taxpayers will not be able to file GSTR-3B if excess ITC is claimed beyond available ledger balance.


This article explains the update in simple language.


✅ What is the Electronic Credit Reversal & Re-claimed Statement?

This ledger tracks ITC that is:

🔹 Temporarily reversed in
Table 4(B)(2) – ITC Reversed (Other than Rule 42/43)

and later

🔹 Re-claimed in
Table 4(A)(5) and Table 4(D)(1)

This system is active from:

✔ August 2023 — Monthly taxpayers
✔ July–September 2023 — Quarterly taxpayers

Purpose of the Reclaim Ledger:

✔ Avoid double reclaim of ITC
✔ Maintain ITC audit trail
✔ Reduce reporting mistakes

You can view the ledger by navigating:

Dashboard ➜ Services ➜ Ledger ➜ Electronic Credit Reversal & Re-claimed


✅ What is the RCM Liability / ITC Statement?

This ledger tracks:

✔ RCM liability paid in
Table 3.1(d) — RCM Tax Payable

and

✔ ITC claimed on RCM in
Table 4A(2) & 4A(3)

This is available from:

✔ August 2024 — Monthly taxpayers
✔ July–September 2024 — Quarterly taxpayers

You can access it here:

Dashboard ➜ Services ➜ Ledger ➜ RCM Liability / ITC Statement


⚠️ Earlier — Only Warning Messages Were Shown

Earlier, if taxpayers:

❌ claimed excess ITC
❌ reclaimed ITC without sufficient reversal balance
❌ claimed more RCM ITC than liability

The portal displayed a warning message, but GSTR-3B filing was still allowed.

Now GSTN has introduced strict system validation.


🚦 New Validation Rules — Very Important

Going forward:

❌ Negative ledger balance will not be allowed
❌ Excess ITC claim will block GSTR-3B filing


🔹 Rule for Reclaim Ledger (ITC Reversal & Re-claim)

ITC reclaimed in Table 4(D)(1) must be:

👉 Less than or equal to:

✔ Closing balance in Reclaim Ledger
+
✔ ITC reversed in Table 4(B)(2) in the same return period

If reclaim exceeds allowed balance →
🚫 GSTR-3B cannot be filed


🔹 Rule for RCM Ledger

RCM ITC claimed in Table 4A(2) & 4A(3) must be:

👉 Less than or equal to:

✔ RCM liability in Table 3.1(d)
+
✔ Closing balance in RCM Ledger

If excess RCM ITC is claimed →
🚫 GSTR-3B filing will be blocked


🚫 If Ledger Balance is Already Negative — Filing Will Be Restricted

A negative balance means:

❌ excess ITC was claimed earlier

To file returns, taxpayer must:


🟡 Case 1 — Negative Balance in Reclaim Ledger

✔ Reverse excess ITC in Table 4(B)(2)

If no ITC is available:

👉 reversal amount will be added to liability



🟡 Case 2 — Negative Balance in RCM Ledger

Taxpayer must either:

✔ Pay additional RCM in Table 3.1(d)
OR
✔ Reduce RCM ITC in Table 4A(2) / 4A(3)

Only after correction →
✔ GSTR-3B filing will be allowed


🧠 Why GSTN Introduced These Ledgers?

To prevent:

❌ wrong or excess ITC reclaim
❌ double claiming of RCM ITC
❌ clerical reporting mistakes
❌ litigation & notices

To promote:

✔ transparent ITC reporting
✔ self-reconciliation
✔ stronger compliance discipline


💡 What Taxpayers Should Do Now

Businesses should start:

✔ Regularly reviewing both ledgers
✔ Reconciling ITC reversal & reclaim
✔ Matching RCM liability vs RCM ITC
✔ Avoiding reclaim without available balance

This will help avoid:

🚫 Return filing blockage
🚫 ITC recovery demands
🚫 Interest & penalties
🚫 GST department notices


🟢 Conclusion — Key Takeaway

GSTN has moved to a ledger-based ITC validation system.

From now on:

✔ ITC can be reclaimed only when reversal balance exists
✔ RCM ITC can be claimed only when liability is paid
✔ Negative balance must be corrected before filing

This ensures:

👉 accurate ITC reporting
👉 better transparency
👉 improved compliance



RB Associates and Tax Matters