Blog/GST & ITC
Credit claimed, payment still open

The invoice is in 2B. The supplier is still unpaid.

Your ageing report says overdue. Your GST working says claimed. Those can both be true. The payment condition needs its own review, tied to the invoice rather than the supplier's closing balance.

Two files that never met

Open your unpaid-invoice list beside your ITC working. Find a supplier whose credit was claimed but whose bill still carries an open balance. That is the starting point for the 180-day ITC check. Not a new OCR run. Not a fresh download of 2B. A comparison between the invoice and what happened to its payment.

I would start here because an ageing report alone cannot answer the tax question. A supplier balance can contain this month's bill, an older credit note and an advance nobody allocated. The balance is real. The story you tell about one invoice may not be.

The CGST Act's Section 16 includes a payment condition: broadly, failure to pay the supplier the value plus tax within 180 days of the invoice can require a credit adjustment. Rule 37 sets out the treatment. Exceptions and amendments matter, so the review below is a working file for your CA, not a return-filing instruction.

The payment check

The 180-day ITC payment check links credit already availed to settlement of the corresponding supplier invoice. It is different from checking whether the invoice appears in GSTR-2B. AP supplies dated payment and adjustment evidence; the tax reviewer decides whether reversal, interest or later re-availment applies under the current rules.

Do not confuse this with the Section 16(4) claim deadline. That asks whether credit can be taken within its statutory time limit. This asks what a payment history means for credit already taken. One date column cannot safely stand in for both.

Follow one invoice, not one balance

Use a fictional bill for ₹1,00,000 plus ₹18,000 tax, total ₹1,18,000. Your working records an ITC claim. The supplier receives ₹60,000 against that bill; a second payment has not happened. The example is deliberately simple. It is not a calculation of the reversal you should file.

An accounts clerk can establish the original amount, the actual allocation of ₹60,000 and the remaining ₹58,000. The tax reviewer then checks how the current rule applies to that partial settlement, including the value-and-tax allocation. I would not let a spreadsheet choose that treatment merely because dividing the numbers is easy.

The invoice and its settlementFictional example
ORIGINAL BILL
₹1,00,000 + ₹18,000 = ₹1,18,000
Invoice date and identity retained
ALLOCATED PAYMENT
₹60,000
Bank reference points to this invoice
OPEN BALANCE
₹58,000
Tax treatment remains a review decision

An allocation is evidence. An unexplained supplier-level debit is not an invoice settlement.

Now make the example awkward. The bank entry says ₹60,000, but the remittance advice allocates it across two invoices. Keep the advice. Without it, your payment column is a guess wearing a bank reference.

An advance needs the same care. It may eventually settle this invoice, or it may remain unapplied while the invoice ages. Record the allocation that actually happened. Do not backdate it to improve the colour of the ageing report.

Credit notes, withholding and disputed deductions also need separate descriptions. A payment less than the invoice total does not tell you, by itself, whether the difference is an agreed settlement, a tax deduction or an unresolved supplier claim. Let the reviewer see the documents rather than compressing them into “paid.”

Build the review file

Keep one row per invoice, with a stable supplier identity and the invoice number exactly as printed. Include the invoice date, value and tax separately, claim period where known, and each settlement reference. If you cannot establish when credit was availed, leave that question open rather than filling the invoice month by habit.

Add the date on which the report was prepared. An open balance on last month's report may be settled today. A reviewer should not have to reconstruct which version of the payment ledger your spreadsheet described.

The exceptions column earns its place. Write “₹60,000 allocated across bills A and B; advice attached” rather than “part paid.” Write the disputed amount and the document explaining it. A useful note lets someone else reach the same evidence without calling the person who typed it.

Working fieldEvidence to retain
Invoice and claimOriginal bill; claim working and period
Payment allocationBank reference and remittance advice
Adjustment or disputeCredit note, correspondence and approval
Tax review outcomeReview date, treatment and supporting rule

This is an extension of a purchase register, not a replacement for the ledger. Your books record the transactions. This file makes the relationship between a claim and its settlement visible.

Leave tax action pending until reviewed. A coloured cell saying “reverse” can quietly turn an AP exception into a filing instruction. If you use a due-date formula, label it as a review trigger and have the relevant convention checked. The formula does not know the exceptions to the law.

After the review, retain what was actually done and in which period. If a supplier is eventually paid, the current law provides a route to re-avail credit subject to its conditions. That next action should be traceable to the earlier adjustment, not treated as a fresh invoice arriving a second time.

Close the payment loop, not just the row

Before each filing review, give the CA the invoice-linked list with its evidence. Work the oldest unresolved allocations first. Ask purchase to settle disputes and treasury to identify remittances. AP should not invent a commercial agreement to close a tax exception.

Do not let a later payment erase the history. Keep the earlier report and the review decision, then add the new settlement. Someone looking back needs to understand why the tax working changed, even when the supplier account now shows zero.

EntryLedger can help produce the invoice side: extracted fields, checks and human review where needed. It does not see your bank allocations, run this ageing calculation or decide an ITC reversal. Passing the document validation gate is not a certificate that every payment condition is met.

The distinction is useful, not disappointing. It tells you which person owns the next action. A blurry date belongs in document review. An unapplied remittance belongs with accounts. The return treatment belongs with the tax reviewer, using the current rules and amendments.

Keep the original bill attached to the settlement story. When the CA asks about an unpaid invoice, send that story. A supplier's closing balance is not an answer to an invoice-level question.

AP records guide, not personalised tax or legal advice. Official source wording checked on 12 October 2026. Have your CA or responsible adviser apply the effective law to your facts before a statutory payment decision or return adjustment.

Sources and scope
  • CBIC
    CGST Act: Section 16

    Payment condition, exceptions and re-availment. Check amendments applicable to the period.

  • CBIC
    GST rules

    Rule 37 and its amendments govern the implementation. This article is an AP working-file guide.

  • GST portal
    Official return user guides

    Portal procedures are separate from invoice extraction and payment allocation.

Frequently asked questions
Does an invoice in 2B settle the 180-day payment check?+

No. GSTR-2B and supplier payment are different evidence. AP needs to link the invoice to its actual settlements and adjustments. The tax reviewer checks the current payment condition and exceptions; portal appearance alone does not establish that the supplier was paid.

What if the supplier was only partly paid?+

Retain the invoice value and tax, the allocated payment and the unpaid balance. Ask the reviewer to apply the current Rule 37 treatment to that evidence. Do not treat the bill as fully settled or use an unreviewed percentage formula as a filing instruction.

Can ITC be re-availed after later payment?+

The law provides for re-availment after payment subject to its conditions. Keep the later settlement linked to the earlier adjustment and have the period and treatment reviewed. Do not enter the original purchase invoice again merely to recreate the credit.

Does EntryLedger maintain this payment tracker?+

No. EntryLedger extracts and validates invoice information. It does not maintain supplier payment allocations, decide reversals or file returns. The tracker described here is a working practice you can use beside your ledger and tax working.

Start with a legible invoice record

Try the extraction and review flow. Payment allocations and ITC decisions stay with your accounts and tax team.