Draft reply for a notice on GST input tax credit (ITC) mismatch: what does a good one look like?
A good ITC mismatch reply references the exact notice and the GSTR period it concerns, sets out the reconciliation workings as an annexure rather than just asserting a number, and explains the mismatch through the reasons that actually apply: delayed credit from a prior month, ineligible credit, tax paid under reverse charge, import IGST credit, or a supplier who hasn't filed. Where the notice's own reply window looks unreasonably short, it's fair to point that out and ask for the standard reply period.
What a strong reply includes
A CAclubindia article with a sample draft reply for this exact notice type structures the response around a few recurring elements.
- Address the reply formally (by RPAD/Speed Post in the sample) and reference the specific notice date and GSTR period it concerns.
- If the reply window given is shorter than usual, say so: the sample draft argues the period given was "less than the 30 days provided in general for any replies."
- Set out the reconciliation workings as an annexure, not just a summary figure.
- Explain the mismatch through the reasons that actually apply to your case: a delayed credit carried from a prior period, credit that's genuinely ineligible, tax paid under reverse charge, IGST paid on imports, or a supplier who simply hasn't filed their return yet.
- Where the comparison basis itself is disputable, say so: the sample draft notes that GSTR-2A "is not available or mandatory" for the period concerned, so a mismatch against it alone isn't automatically a discrepancy in the taxpayer's books.
FAQs
What are the common legitimate reasons for an ITC mismatch?
The sample draft's list: a credit legitimately delayed from an earlier month, ineligible credit, tax paid under reverse charge, IGST credit on imports, and a supplier who hasn't filed their return.
Should I attach my reconciliation working, or just state a corrected figure?
Attach the working as an annexure: the sample draft treats the reconciliation itself as the evidence, not a substitute for it.
Can I question a notice's reply deadline if it's shorter than usual?
Yes, the sample draft directly raises that a shorter-than-30-day window isn't the general practice for replies, as one of its points.
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Last reviewed 2026-10-15
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