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Microlesson · 5-min read

ITC Reversal on Transition / Sale of Capital Goods (Section 18)

# Special Cases Leading to Reversal of Credit [Section 18]

When a taxpayer's status moves from an ITC-eligible position to a non-ITC position, the credit attributable to existing stock must be reversed (paid back). Section 18(4) and 18(6) cover four such scenarios.

## The Four Reversal Triggers

#Trigger EventWhat to ReverseReversal Date Reference
1Regular supplier → Composition supplierITC on Inputs (RM/SFG/FG) + Capital GoodsDay immediately preceding switch-over
2Taxable supplies → Exempt suppliesITC on Inputs (RM/SFG/FG) + Capital GoodsDay immediately preceding date taxable became exempt
3Cancellation of RegistrationITC on Inputs (RM/SFG/FG) + Capital GoodsDay immediately preceding date of cancellation
4Supply (sale) of Capital Goods on which ITC was takenHigher of: (a) ITC less 5%/qtr (b) Tax on transaction value

## How to Quantify the Reversal

### A. For Inputs (RM / SFG / FG)

SituationMethod
Invoice availableProportionate reversal based on invoice value
Invoice NOT availableReversal based on prevailing market price as on relevant date — certified by practicing CA/CMA

### B. For Capital Goods

  • Useful life is statutorily fixed at 5 years = 60 months.
  • Reverse ITC for the remaining useful life in full months.
  • Formula:

$$\text{Reversal} = \frac{\text{Total ITC} \times \text{Remaining months}}{60}$$

  • The reversed amount is added to output tax liability.

### C. For Sale of Capital Goods [Section 18(6)]

Amount payable = Higher of:

1. Total ITC – (5% per quarter or part quarter from invoice date), OR

2. Tax on transaction value of sale

> Exception: For refractory bricks, jigs, moulds, dies, tools, fixtures — pay tax on transaction value directly (no comparison needed).

## Balance Treatment Rule

ScenarioTreatment
ITC balance > reversal requiredExcess credit lapses (cannot be claimed/refunded)
ITC balance < reversal requiredShortfall added to output tax liability (pay in cash)

Worked example

### Example 1

Example — Sale of Capital Goods (from notes)

Ravi Ltd. purchased a machine on 1st June 2024 for ₹10,00,000 (excl. tax) at 18% GST. Machine sold on 15th October 2026 for ₹4,00,000 (excl. tax).

Original ITC = 10,00,000 × 18% = ₹1,80,000

Quarters from Jun 2024 to Oct 2026 (counting part quarters): Q2-2024 (part), Q3-2024, Q4-2024, Q1-2025, Q2-2025, Q3-2025, Q4-2025, Q1-2026, Q2-2026, Q3-2026, Q4-2026 (part) = 11 quarters

Option A — ITC reversal route:

= 1,80,000 − (1,80,000 × 5% × 11) = 1,80,000 − 99,000 = ₹81,000

Option B — Tax on transaction value:

= 4,00,000 × 18% = ₹72,000

Tax payable = Higher = ₹81,000

### Example 2

Example — Capital Goods Reversal on Cancellation

XYZ Ltd. surrenders registration on 30th November 2026. A machine purchased on 1st January 2025 had ITC of ₹6,00,000 claimed.

Months used (Jan 2025 – Nov 2026) = 23 months

Remaining useful life = 60 − 23 = 37 months

Reversal = 6,00,000 × 37/60 = ₹3,70,000

This ₹3,70,000 is added to the output tax liability.

⚠️ Common exam mistakes

  • Counting remaining useful life in DAYS instead of FULL MONTHS — the law uses full months out of 60.
  • Assuming the lower of the two amounts applies for sale of capital goods — it's actually the HIGHER.
  • Forgetting the special rule for refractory bricks/jigs/moulds/dies/tools/fixtures, where tax on transaction value is paid directly with no comparison.
  • Believing leftover ITC after reversal can be refunded — it LAPSES.
  • Not obtaining a CA/CMA market-price certificate when invoice is unavailable for input stock reversal.
Bare-Act text Section 18(4) and 18(6) · CGST Act, 2017 · click to expand
Section 18(4): Where any registered person who has availed of input tax credit opts to pay tax under section 10 or, where the goods or services or both supplied by him become wholly exempt, he shall pay an amount, by way of debit in the electronic credit ledger or electronic cash ledger, equivalent to the credit of input tax in respect of inputs held in stock and inputs contained in semi-finished or finished goods held in stock and on capital goods, reduced by such percentage points as may be prescribed, on the day immediately preceding the date of exercising of such option or the date of such exemption. Section 18(6): In case of supply of capital goods or plant and machinery on which input tax credit has been taken, the registered person shall pay an amount equal to the input tax credit taken on the said capital goods or plant and machinery reduced by such percentage points as may be prescribed or the tax on the transaction value of such capital goods or plant and machinery determined under section 15, whichever is higher.
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