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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsNot automatically in every case. Whether an officer may deny input tax credit (ITC) for a GSTR-2A mismatch depends on the tax period, the transaction and its evidence. For ordinary supplier-reported domestic invoices from 1 January 2022, the central-law test generally turns on whether invoice details were reported and communicated in GSTR-2B—not simply on whether the credit appears in GSTR-2A.
Why the tax period changes the answer
The rules governing invoice mismatches changed over time. A decision about ITC should use the version of section 16 and rule 36 applicable to the disputed tax period, rather than applying today’s GSTR-2B condition to older returns or treating an old mismatch tolerance as a current allowance.
| Tax period | Mismatch framework | What the published guidance establishes |
|---|---|---|
| 1 July 2017–31 March 2019 | Section 16 eligibility conditions applied. Rule 36(4) had not yet taken effect. | CBIC Circular 193/05/2023-GST (17 July 2023) says rule 36(4) took effect on 9 October 2019. The specific Circular 183 guidance identified for later pre-2022 periods should not be treated as a blanket entitlement for every earlier mismatch. |
| 1 April–8 October 2019 | Section 16 conditions applied; rule 36(4) was not yet effective. | CBIC Circular 193 says Circular 183/15/2022-GST guidance applies in toto to this period. That guidance is not a rule that every credit absent from 2A is automatically allowable. |
| 9 October–31 December 2019 | Rule 36(4) permitted a limited amount of unreported credit. | The ceiling was 20% of eligible credit reported by suppliers, as stated by CBIC Circular 193 (17 July 2023). It was a ceiling, not a blanket ITC entitlement. |
| 1 January–31 December 2020 | Rule 36(4) continued with a lower ceiling. | The ceiling was 10% of eligible reported credit, as stated by CBIC Circular 193. CBIC describes a cumulative adjustment for February–August 2020 in the September return under the applicable amendment. |
| 1 January–31 December 2021 | Rule 36(4) continued with a further reduced ceiling. | The ceiling was 5% of eligible reported credit, as stated by CBIC Circular 193. CBIC describes a cumulative adjustment for April–June 2021 in the June return under the applicable amendment. |
| From 1 January 2022 | Section 16(2)(aa) and the amended rule introduced a supplier-reporting and GSTR-2B communication condition for covered supplies. | CBIC Circular 193 says ITC for a covered supply is available only to the extent the supplier reports it in GSTR-1 or IFF and the details are communicated in GSTR-2B. A later Gauhati High Court ruling qualifies how this is applied to bona fide purchasers facing supplier default. |
The historical percentages are not general mismatch allowances. They applied to unreported invoices against eligible credit reported by suppliers, within the relevant rule version and subject to the other conditions for claiming ITC.
What must be checked besides GSTR-2A
For periods before 1 January 2022
GSTR-2A mismatches were considered under the statutory eligibility conditions and, from 9 October 2019, the applicable version of rule 36(4). CBIC Circular 193 explains that Circular 183/15/2022-GST provides verification guidance for specified pre-2022 periods, including 1 April 2019–31 December 2021, subject to the relevant rule ceiling. The circulars also address which proceedings their clarifications cover: CBIC says they apply to ongoing scrutiny, audit, investigation and pending adjudication or appeal within the stated scope, but not completed proceedings. The detailed requirements depend on the relevant circular and case facts.
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For ordinary domestic invoices from 1 January 2022
Section 16(2)(aa) requires the supplier to furnish invoice or debit-note details and those details to be communicated to the recipient, with the applicable rule referring to GSTR-2B. CBIC Circular 193 states that, for covered supplies from this date, ITC is not to be allowed unless the supplier reports the details in GSTR-1 or the Invoice Furnishing Facility (IFF) and they are communicated in GSTR-2B. The circular summarizes this as ITC being available only to the extent communicated in GSTR-2B.
That is not the only eligibility test. Section 16(2) also includes conditions concerning possession of a prescribed tax invoice, receipt of the goods or services, payment of tax to the Government subject to the statute, and filing the recipient’s return. Read the provision with applicable amendments—including clause (ba)—and the other rules relevant to the transaction. Paying the supplier’s invoice, by itself, does not prove every statutory condition is met.
Important court qualifications—and their limits
Gauhati High Court: bona fide purchaser and a defaulting supplier
In MCLEOD Russel India Limited (Gauhati High Court, 9 December 2025), the court did not strike down section 16(2)(aa). It read the provision down temporarily: where a supplier acts truant, a bona fide purchaser must have an opportunity to establish its bona fides with tax invoices and other documents before ITC is denied. The court’s approach is to last until CBIC provides a practical solution.
This is a material qualification for a purchaser whose supplier has defaulted, but it is not a Supreme Court ruling establishing a nationwide rule. The reviewed authorities do not establish whether a later Supreme Court decision, decisions from other High Courts or a later CBIC solution has changed the position after that judgment. The court, date, jurisdiction and subsequent developments therefore matter when assessing a particular dispute.
Karnataka High Court: a 2A gap that reflected the transaction type
In Biocon Limited (Karnataka High Court, 30 April 2026), a dispute for 2018–19 included import and SEZ credits that the record said were not reflected in GSTR-2A by system design. The court noted that a Bill of Entry was relevant evidence for import credit and set aside that part of the demand. The decision shows why the cause of a mismatch and the applicable transaction documents matter; it does not decide the post-2022 rule for ordinary domestic supplier invoices.
Earlier-period and procedural examples
Hindustan Construction Company Ltd (Karnataka High Court, 28 November 2025) concerned 2017–18 and 2018–19 mismatch proceedings and discussed the historical CBIC framework. It is context for those earlier periods, not a ruling on post-2022 GSTR-2B eligibility.
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In Andromeda Sales and Distribution (Telangana High Court, 10 February 2026), the taxpayer had not supplied supporting evidence, answered the show-cause notice or attended hearings. The court directed it to pursue the appellate remedy. That procedural outcome illustrates the risk of leaving a notice unanswered; it does not establish that a GSTR-2A mismatch alone always proves ITC ineligible.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to respond to an ITC mismatch notice
Organize the response invoice by invoice and tax period by tax period. A reconciliation that identifies the precise cause of each gap is more useful than a general assertion that credit was paid for or claimed in the return.
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Outbyte PC Repair FREERepair Windows errors before they cause bigger problemsFix Now →Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →- Identify the disputed entries. List each invoice or debit note, supplier, tax period, tax amount and the amount claimed in GSTR-3B.
- Reconcile the returns and books. Compare the purchase ledger with GSTR-3B, GSTR-2A and GSTR-2B. State whether the issue is non-reporting, late reporting, incorrect particulars, or a transaction type for which the document is not expected to appear in the same way.
- Apply the period-specific rule. Check the applicable section 16 and rule 36 provisions, any relevant historical rule 36(4) ceiling, and whether the matter falls within the scope of CBIC Circular 183 or Circular 193.
- Attach transaction evidence. Include the prescribed invoice or debit note, evidence of receipt of goods or services, payment records, supplier communications and available return or reporting evidence. For import credit, include the relevant Bill of Entry; use documents specific to other transaction types where applicable.
- Address every statutory condition and notice requirement. Explain how each disputed credit meets the conditions that apply, respond within the notice’s deadline and follow the stated hearing and appeal procedure. Do not assume that a mismatch explanation cures a separate eligibility or procedural defect.
Because the result can turn on amendments, the precise transaction and the jurisdiction’s binding precedents, a taxpayer facing an actual demand should have an Indian GST professional review the notice, evidence and deadlines.
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