CA Final · Indirect Tax Laws

GST — Input Tax Credit (Advanced)

Chapter 2 · 3 formulas · 4 exam-critical pointers

Core concepts

  1. 01ITC eligibility (Sec 16): documents, receipt of supply, supplier paid tax, return filed.
  2. 02Sec 17(5) Blocked credits — motor vehicles (with exceptions), food/club/health, works contract, plant & machinery exception.
  3. 03Apportionment (Sec 17(2)+ Rule 42/43) — exempt vs taxable, business vs personal.
  4. 04Sec 18 — Special circumstances (new registration, switch composition→regular, exempt→taxable).
  5. 05Job work (Sec 19, 143) — credit allowed if inputs/CG returned within 1 yr / 3 yrs.

Flowchart summary

ITC Decision Flow | Eligible expense? -- check Sec 17(5) | Used for taxable supply only? -- if mixed, apportion | Documents + Supplier paid + Return filed? | ITC available -> Cr to Electronic Credit Ledger

Exam-critical pointers

  • GSTR-2B auto-populated — Sec 16(2)(aa) requires reflection here for ITC.
  • 180-day non-payment to supplier triggers ITC reversal with interest; re-avail on payment.
  • Sec 17(5) blocked: works contract for immovable property (except plant & machinery).
  • ISD distinguished from cross-charge — ISD only for common input services.

Elaborative notes

Input Tax Credit under GST (Sections 16 & 17)

ITC is GST's flagship feature — the mechanism that prevents tax-on-tax and

makes GST a value-added tax in practice. It's also IDT's most-tested area:

every attempt under the new scheme has tested either eligibility, the

blocked-credit list, or the reversal mechanics. Expect 10-14 marks of ITC

content in any IDT paper.

1. The four conditions for claiming ITC (Section 16)

A registered person can take credit of input tax charged on a supply of

goods or services used in the course or furtherance of business, provided

all four conditions are met:

  1. Possession of a tax invoice / debit note (or other prescribed

document, e.g., bill of entry for imports)

  1. Receipt of the goods or services — including the "bill-to-ship-to"

deemed-receipt rule for principal-to-job-worker cases

  1. Tax actually paid by the supplier to the government — this is the

critical practical hurdle, often tested via GSTR-2B reconciliation

  1. Filing of GSTR-3B by the recipient for the relevant period

Time limit: ITC must be availed by **30 November following the end of the

financial year**, or the date of filing the relevant annual return,

whichever is earlier (Section 16(4)). Miss this date and the credit lapses

permanently.

A fifth practical condition introduced via Rule 36(4) and now codified in

Section 16(2)(aa): the invoice must be reflected in the recipient's

GSTR-2B. Mismatches mean no credit even if everything else is in order.

2. Blocked credits (Section 17(5))

Section 17(5) lists 14 categories where ITC is blocked regardless of

business use. Memorise the list — examiners test specific clauses:

ClauseBlocked
(a)Motor vehicles ≤ 13 seats (with exceptions for further supply, transport business, driving schools)
(aa)Vessels and aircraft (similar exceptions)
(ab)Insurance / repair / maintenance of (a) and (aa)
(b)Food and beverages, outdoor catering, beauty treatment, health services, life/health insurance
(c)Membership of club / health / fitness centre
(d)Rent-a-cab, life/health insurance, travel benefits to employees on vacation
(e)Travel benefits
(f)Goods/services for personal consumption
(g)Goods lost, stolen, destroyed, written off, or disposed of by way of gift / free samples
(h)Works contract services for construction of immovable property (except plant & machinery)
(i)Goods/services received for construction of immovable property on own account
(j)Composition levy supplies
(k)Non-resident taxable person (except on imports)
(l)CSR activities

Two of these (h, i) generate the most exam questions — the "construction

of immovable property" block. Plant & machinery (P&M) is not immovable

property for ITC purposes, so credit on P&M installation is allowed.

3. Apportionment when supplies are partly for taxable and partly for

exempt/non-business purposes (Section 17(1)-(4) + Rule 42/43)

If a registered person makes both taxable and exempt supplies (e.g., a

bank making interest-earning loans alongside fee-based services), ITC must

be apportioned. Two regimes:

3.1 Inputs and input services (Rule 42)

Step-by-step computation:

  1. T = Total ITC on inputs/input services in the tax period
  2. T1 = ITC attributable exclusively to non-business
  3. T2 = ITC attributable exclusively to exempt supplies
  4. T3 = ITC on blocked credits (Section 17(5))
  5. C1 = T − (T1 + T2 + T3) → common credit
  6. T4 = ITC attributable exclusively to taxable supplies (including

zero-rated)

  1. C2 = C1 − T4
  2. D1 = C2 × (Exempt turnover / Total turnover) → reversal for exempt
  3. D2 = 5% × C2 → reversal for non-business (deemed)
  4. C3 = C2 − (D1 + D2) → eligible common credit

3.2 Capital goods (Rule 43)

For capital goods used for mixed purposes, the ITC is averaged over 60

months (5 years) and the exempt portion reversed monthly.

4. ITC reversal (Section 16(2) second proviso + Rule 37)

If the recipient fails to pay the supplier within 180 days from the

invoice date, the ITC claimed must be reversed with interest. When payment

is eventually made, the recipient can re-avail the credit — there's no

time limit for the re-claim once the conditions are met.

5. ITC on capital goods

ITC on capital goods is fully available in the period of receipt

(subject to the four conditions), unless they're used for mixed purposes

(Rule 43 apportionment). However:

  • Depreciation under Income Tax Act cannot be claimed on the ITC portion

(the recipient must choose: credit OR depreciation, not both)

  • On sale of capital goods, the recipient pays GST on the higher of

(a) ITC reduced by 5% per quarter of use, or (b) transaction value × rate

6. ICAI exam patterns

Question shapeTypical marks
Eligibility check for a specific transaction4-6
Blocked-credit clause application4
Rule 42 apportionment computation6-8
Rule 43 capital goods reversal4
180-day reversal mechanism4
Re-credit on payment after reversal2

ITC appears in every IDT attempt — typically 14 marks across one full

question + sub-parts in other questions.

7. The 60+ marks topper convention

  • State the section first: "Per Section 16(2) read with Section 17(5)

of the CGST Act, 2017..." — earns the authority mark

  • List the four conditions explicitly when checking eligibility
  • Use short forms inside working notes only: ITC, CGST, SGST, IGST.

Spell out "Input Tax Credit (ITC)" at first use in theory answers

  • Box the final eligible credit / reversal figure
  • Cite the rule for apportionment: "Per Rule 42 of the CGST Rules, the

common credit reversal is computed as follows..."

  • State the consequence if credit lapses: "The credit lapsed on 30

November 2026 per Section 16(4) and cannot be claimed thereafter"

Worked examples

Worked example — Rule 42 apportionment

Trans-South Bank Ltd. has the following ITC and turnover data for the

month of April 2026:

Particulars
Total ITC on inputs and input services (T)80,00,000
ITC exclusively for non-business use (T1)5,00,000
ITC exclusively for exempt supplies (T2)12,00,000
ITC on blocked credits Sec 17(5) (T3)3,00,000
ITC exclusively for taxable supplies incl. zero-rated (T4)30,00,000
Total turnover (taxable + exempt)4,00,00,000
Exempt turnover (interest income mainly)1,00,00,000

Step 1 — Common credit C1

C1 = T − (T1 + T2 + T3)

C1 = 80,00,000 − (5,00,000 + 12,00,000 + 3,00,000)

C1 = 80,00,000 − 20,00,000 = **₹60,00,000**

Step 2 — Non-attributable common credit C2

C2 = C1 − T4

C2 = 60,00,000 − 30,00,000 = **₹30,00,000**

Step 3 — Exempt portion D1

D1 = C2 × (Exempt T/O ÷ Total T/O)

D1 = 30,00,000 × (1,00,00,000 ÷ 4,00,00,000)

D1 = 30,00,000 × 0.25 = **₹7,50,000**

Step 4 — Deemed non-business reversal D2

D2 = 5% × C2 = 5% × 30,00,000 = **₹1,50,000**

Step 5 — Eligible common credit C3

C3 = C2 − (D1 + D2) = 30,00,000 − (7,50,000 + 1,50,000) = **₹21,00,000**

Step 6 — Total ITC reversal

Total reversal = T1 + T2 + T3 + D1 + D2

= 5,00,000 + 12,00,000 + 3,00,000 + 7,50,000 + 1,50,000 = **₹29,00,000**

Step 7 — Net ITC eligible

Net ITC eligible = T − Total reversal = 80,00,000 − 29,00,000 = **₹51,00,000**

Cross-check: T4 + C3 = 30,00,000 + 21,00,000 = ₹51,00,000 ✓

Final answer: Net ITC available for April 2026 = ₹51,00,000.

Authority: Section 17(1)-(4) CGST Act read with Rule 42 of the CGST Rules.

Pitfalls examiners flag

Common pitfalls

  1. Using the wrong time limit. Pre-2022 it was September; now it's

November. Use the post-amendment date.

  1. Treating plant & machinery as blocked. P&M is explicitly carved out

from the immovable-property block (Section 17(5)(c)/(d) Explanation 2).

ITC on installation of P&M is allowed.

  1. Forgetting Section 16(2)(aa). Invoice must appear in GSTR-2B. Even

if the four classic conditions are met, mismatched invoices block the

credit.

  1. Reversing ITC on motor vehicles bought for further supply. ITC is

allowed for motor vehicles bought for further supply, transport of

passengers/goods, or driving schools. Don't blanket-block.

  1. Double-claiming depreciation and ITC. If depreciation is claimed

under the IT Act on the tax component, ITC is not available. Section

16(3) treats this as an election.

  1. Confusing Rule 42 and Rule 43. Rule 42 is for inputs and input

services (monthly true-up). Rule 43 is for capital goods (60-month

averaging). Don't mix the formulas.

30-second revision card

Input Tax Credit — 30-second recap

  • 4 conditions: invoice, receipt, supplier-paid, GSTR-3B filed
  • 5th practical: invoice in GSTR-2B (Sec 16(2)(aa))
  • Time limit: 30 Nov following FY end OR annual return — whichever earlier
  • 14 blocked credit clauses (Sec 17(5)) — memorise (a)(b)(g)(h)(i)
  • 180-day rule: reverse if supplier unpaid; re-credit on payment
  • Rule 42 (inputs/services) + Rule 43 (capital goods) for mixed-use
  • ITC vs depreciation — choose one, not both
  • Cite section + rule; box final figure; short-forms in WN only

Make it click