ITC eligibility self assessment: the fifteen questions that decide the claim

A working checklist, in the order an adjudicating officer will ask them.

Entitlement

One. Do you hold a tax invoice, debit note, bill of entry or prescribed document containing the particulars required by Rule 46, with your correct GSTIN?

Two. Have the goods or services actually been received, and can you prove it with a document generated by someone other than you?

Three. Does the invoice appear in your GSTR-2B, and did you act on it in the Invoice Management System with a recorded basis?

Four. Has the return under Section 39 for the period been furnished?

Five. Is the credit availed within the Section 16(4) outer date for the financial year of the invoice or debit note?

Restriction

Six. Is the supply within any clause of Section 17(5), and if so does an exception apply, and can you prove the exception?

Seven. Is the input used partly for exempt supplies or non business purposes, requiring apportionment under Rule 42 or 43?

Eight. Is the recipient of the supply the registration claiming the credit, or should it have been distributed through the Input Service Distributor?

Nine. Is the tax charged the tax properly payable, or has the supplier charged an incorrect rate or the wrong head?

Ten. Is the credit of a category that Rule 86B affects for the month, requiring one percent in cash?

Continuing conditions

Eleven. Has the supplier been paid the value and tax within one hundred and eighty days, for Rule 37?

Twelve. Has the supplier filed its GSTR-3B for the relevant period, for Rule 37A, and is the September check diarised?

Thirteen. Is the supplier's registration active, and do you hold a dated record of its status at the time of the transaction?

Fourteen. If the credit is later disputed, can you show consumption — the stock movement, production record or deliverable, and the outward supply that used it?

Fifteen. Is there a contemporaneous internal note recording the basis of the claim on any judgment call?

What to do on Monday

1. Adopt the fifteen questions as the credit sign off for any invoice above a value threshold you set.

2. Store the answers with the credit register, not in an email chain.

3. Review the list annually against amendments; the questions change when the rules do.

Questions we are asked on this

How often should this be run?

Monthly for the top suppliers by value, and once for every new supplier or new expense category.

What if we cannot answer question two?

Then the credit is at risk regardless of the paperwork, because Ecom Gill makes receipt and genuineness the substance of the claim.

Is a note written after a notice of any use?

It is an argument, not evidence. The value of the note lies entirely in its date.

In this cluster

• Input tax credit under GST: the complete 2026 position
• Section 16(2)(c): can your ITC be denied because the supplier did not pay tax?
• Section 16(4) time limit for claiming ITC: what survives after the amnesty
• GSTR-2A and 2B mismatch notices: how to answer without conceding
• Blocked credits under Section 17(5): the clause by clause map
• Safari Retreats: what the Supreme Court decided on ITC for construction, and what Parliament then undid
• ITC on canteen, transport, insurance and other employee benefits
• ITC reversal under Rules 42 and 43: working the formula correctly
• Rule 37: ITC reversal when you do not pay your supplier within 180 days
• Rule 37A: reversal where your supplier did not file its GSTR-3B

GST Insights is published by AMLEGALS for general information. Law stated as on 3 September 2026. Not advice on any particular set of facts; not an advertisement or a solicitation under Rule 36 of the Bar Council of India Rules. Readers with a question on their own facts may write to the GST practice of their own accord.