Question
Here is a pertinent question I want to check
your view regarding eligibility of ITC on post supply commercial credit note.
AAR has given adverse ruling in MRF case as below: -
https://www.business-standard.com/article/economy-policy/mrf-can-avail-input-tax-credit-only-for-invoice-value-tamil-nadu-authority-119031900114_1.html
However I strongly believe that discount particularly when it is of pass through
nature i.e. given by manufacturer to the super stockist and same discount passed
by the super stockist to the wholesalers, then for the super stockist it is
actually just an adjustment entry and hence his proportionate ITC should not be
reversed.....
Answer
In case of MRF, the discount is given post supply
but it was as per agreement decided before supply.
In your case discount is given post supply by issuing commercial credit note, so
the aforesaid ruling will not apply in your case and you are not liable to
reverse the ITC availed because in commercial credit note tax amount is not
reflected, only value is adjusted. Therefore there is no need for reversal of
ITC against commercial credit note (Reply dt 04/06/2019)