1. ITC Balance in Balance Sheet as of 31st March 2025
In the balance sheet, you must show only ITC that is actually available in your Electronic Credit Ledger (ECL) as of 31-March-2025.
Reasoning:
Section 16(2)(c) of the CGST Act requires that tax must have been actually paid to the Government by the supplier. Until the supplier uploads the invoice in their GSTR-1 and it reflects in your GSTR-2B, your entitlement is not finalized.
Section 16(2)(aa) (inserted in 2021) ties ITC availment to reflection in GSTR-2B. If it is not in 2B as on March, you cannot take credit as on that date.
Hence, the balance sheet should reflect the ITC balance that is actually usable as on 31-March, not “deemed available” later.
Therefore, your understanding is correct:
Show in assets: ITC as per GST portal balance as on 31-March-2025.
Do not include: ITC which became available only after April (even if invoice/service was of March).
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2. How to Present “Missed” ITC in Accounts
Even though you cannot show it as ITC in your balance sheet on 31-March:
You may treat that portion as “GST Receivable” under Current Assets” until the invoice is reflected and ITC is taken in April 2025.
This way, your books correctly capture the fact that tax has been paid and credit is expected, but you don’t overstate the “ITC Ledger balance” as on March.
This is a common accounting treatment in practice.
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3. Supplementary Question – Back-dated Invoice
Your supplier issuing an invoice dated 6-March-2025 but sending it to you in April raises an important point:
Under Section 31 of CGST Act:
For services, the supplier must issue a tax invoice within 30 days from the date of supply (for normal taxpayers).
If service was provided in March, an invoice dated 6-March is valid if actually issued on that date.
If the supplier only prepared it later in April but back-dated it, that is technically non-compliance / irregular practice.
From your side, you can still avail ITC as long as the invoice eventually appears in your GSTR-2B.
But strictly, suppliers should not “create invoices later and backdate.” They should issue on or before the prescribed time limit.
So while it doesn’t usually create a problem for you as recipient (since the credit is allowed when it reflects in 2B), the supplier may face procedural issues if authorities scrutinize the timing.
Thanks
CA Damini Agarwal
www.thewitcorp.com