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Microlesson · 5-min read

ITC Availment on Transition (Section 18) - Special Cases

# Special Cases Enabling Availment of ITC [Section 18]

## When does Section 18(1) Apply?

Section 18 grants the right to claim ITC on existing stock when a taxpayer's status changes from a non-ITC position to an ITC-eligible position. There are four trigger events:

#Trigger EventEligible CreditEffective Date for Stock
1Composition supplier → Regular supplierInputs (RM/SFG/FG) + Capital GoodsDay immediately preceding date of liability to pay tax under regular scheme
2Exempt supplies become Taxable suppliesInputs (RM/SFG/FG) + Capital GoodsDay immediately preceding date exempt supply became taxable
3Unregistered → Liable to register (applied within 30 days)Inputs (RM/SFG/FG) only — No Capital GoodsDay immediately preceding date of becoming liable to register
4Unregistered → Voluntarily registeredInputs (RM/SFG/FG) only — No Capital GoodsDay immediately preceding date of grant of registration

> Memory hook: Capital Goods credit is available only in cases 1 & 2 (where the person was already registered). For cases 3 & 4 (fresh registration), only input stock qualifies.

## Key Conditions for Availment

1. One-year invoice rule — ITC can be availed only if the invoice is not older than 1 year. This applies to capital goods also.

2. Capital goods reduction formula

$$\text{ITC on CG} = \text{Total ITC} - (5\% \text{ per quarter or part of quarter from invoice date to availment date})$$

A 'quarter' under GST = Jan–Mar / Apr–Jun / Jul–Sep / Oct–Dec.

3. Exempt → Taxable carve-out: ITC on capital goods is available only if the supplier was already registered while making exempt supplies. If a person was unregistered during the exempt phase and registers when supply becomes taxable, no CG credit.

4. Form ITC-01 — Electronic declaration to be filed within 30 days from the relevant date, containing details of inputs and CG.

5. CA/CMA Certification — If aggregate credit (CGST + SGST/UTGST + IGST) exceeds ₹2,00,000, the declaration must be certified by a CA/CMA in practice.

## Decision Flow

```

Status Change?

[Was the person already registered while in non-ITC state?]

├── Yes → Inputs + Capital Goods eligible

└── No → Only Inputs eligible (no CG)

[Are invoices < 1 year old?] → if No, no credit

[File ITC-01 within 30 days]

[If credit > ₹2 lakh → CA/CMA certificate]

```

Worked example

### Example 1

Example 1 — Withdrawal from Composition Scheme

Mr. Ravi withdraws from the composition scheme on 1st October.

Question: On what date's stock can ITC be claimed?

Answer: ITC on inputs (RM/SFG/FG) and capital goods held in stock as on 30th September (day immediately preceding the date of liability under the regular scheme). Both input and CG credit are available because Ravi was already registered as a composition dealer.

### Example 2

Example 2 — New Registration after Crossing Threshold

Mr. Ravi becomes liable to register on 1st June, applies for registration on 25th June (within 30 days), and registration is granted on 15th July.

Question: What can he claim?

Answer: ITC on inputs in stock as on 31st May (day immediately preceding the date of becoming liable to register). Capital goods are NOT eligible because this falls under Case 3 (fresh registration).

### Example 3

Example 3 — Capital Goods Reduction Calculation

ABC Ltd. converts from composition to regular on 1st October 2026. Machine purchased on invoice dated 5th February 2025 for ₹10,00,000 + 18% GST (₹1,80,000 ITC).

Quarters from Feb 2025 to Oct 2026: Q1 2025 (part), Q2 2025, Q3 2025, Q4 2025, Q1 2026, Q2 2026, Q3 2026, Q4 2026 (part) = 8 quarters/part quarters

Eligible ITC = 1,80,000 − (1,80,000 × 5% × 8) = 1,80,000 − 72,000 = ₹1,08,000.

⚠️ Common exam mistakes

  • Claiming ITC on capital goods in cases of fresh registration (whether voluntary or after crossing threshold). CG credit is permitted ONLY where the person was already registered (composition→regular OR exempt→taxable while registered).
  • Forgetting to reduce CG credit by 5% per quarter or PART of quarter from invoice date — even one day in a quarter counts as a full quarter.
  • Missing the 30-day deadline for filing Form ITC-01 from the relevant date.
  • Treating an invoice older than 1 year as eligible — the 1-year invoice rule blocks ALL credit (inputs and CG) under Section 18(1).
  • Forgetting the ₹2,00,000 aggregate threshold (CGST + SGST/UTGST + IGST combined) that mandates CA/CMA certification.
Bare-Act text Section 18(1) · CGST Act, 2017 · click to expand
Section 18(1) — Availability of credit in special circumstances: Subject to such conditions and restrictions as may be prescribed — (a) a person who has applied for registration within thirty days from the date on which he becomes liable to registration shall be entitled to take credit of input tax in respect of inputs held in stock and inputs contained in semi-finished or finished goods held in stock on the day immediately preceding the date from which he becomes liable to pay tax; (b) a person who takes voluntary registration shall be entitled to take credit of input tax in respect of inputs held in stock and inputs contained in semi-finished or finished goods held in stock on the day immediately preceding the date of grant of registration; (c) any registered person who ceases to pay tax under section 10 (composition) shall be entitled to take credit of input tax in respect of inputs held in stock, inputs contained in semi-finished or finished goods held in stock and on capital goods on the day immediately preceding the date from which he becomes liable to pay tax under section 9; (d) where an exempt supply of goods or services by a registered person becomes a taxable supply, such person shall be entitled to take credit of input tax in respect of inputs held in stock and inputs contained in semi-finished or finished goods held in stock relatable to such exempt supply and on capital goods exclusively used for such exempt supply on the day immediately preceding the date from which such supply becomes taxable.
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