INPUT TAX CREDIT (ITC) PROVISIONS. CA Nammitta Gangwal Nilange LCS, DISA, GST Faculty R. I. Nilange & Co. Chartered Accountant

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1 INPUT TAX CREDIT (ITC) PROVISIONS LCS, DISA, GST Faculty R. I. Nilange & Co. Chartered Accountant

2 WHAT SHOULD WE KNOW UNDER ITC? Sec. 16 Eligibility & Conditions for taking ITC Sec. 19 Taking ITC in respect of inputs & capital goods sent for JOB WORK Se. 17 Apportionment of credit & blocked credits I T C Sec Manner of distribution of credit by ISD Sec. 18 Availability of credit in special circumstances Sec Manner of recovery of credit distributed in excess 2

3 ELIGIBILITY FOR TAKING ITC SEC.16 Input tax credit: means the credit of input tax in terms of section 2(63). Input tax: "Input tax" in terms of section 2(62) in relation to a registered person, means the central tax, State tax, integrated tax or Union territory tax charged on any supply of goods or services or both made to him and includes integrated goods and service tax (IGST) charged on import of goods tax payable on reverse charge basis under IGST Act/SGST Act/CGST Act/UTGST Act. but excludes tax paid under composition levy. Input Tax Credit available only on inward supplies of goods/services from a registered person Input Tax Credit available only if the input goods/services are used for the business and not for personal purposes 3

4 TAX CREDIT UNDER GST CGST CENTRAL CGST IGST STATE SGST SGST IGST INTEGRATED IGST IGST CGST SGST 4

5 CONDITIONS FOR TAKING ITC SEC.16 POSSESSION OF INVOICE ITC can be taken on the basis of any of the following document - -(i) Invoice issued under section 31 (ii) Debit note issued under section 34 INTENTION The said goods or services or both are used or intended to be used in the course or in the furtherance of his business; RECEIPT OF BOTH He has received the said goods or services or both subject to job-work facilities and restrictions relating to input tax credit in Section 19 UPLOAD INVOICE The supplier has uploaded the relevant invoice on the GSTN 5

6 CONDITIONS FOR TAKING ITC SEC.16 PAYMENT OF TAX The supplier has paid the said amount of tax (as charged in the invoice) to appropriate Government in cash or by way of utilization of input tax credit, as admissible [Sec. 41 ]; RETURN He claimant of input tax credit has furnished return under section 39 in FORM-GSTR 2; GOODS RECD.IN INSTALLMENTS If goods are received in installments against a single invoice, credit can be taken upon receipt of last installment of goods IF DEPRECIATION CLAIMED No ITC will be allowed if depreciation have been claimed on tax component of a capital goods. 6

7 CONDITIONS FOR TAKING ITC SEC.16 INVOICE DETAILS Said Document must contain all the prescribed particulars specified in the invoice Rules. Can have additional Points but NOT LESS. PAYMENT OF INVOICE Compulsory payment to the supplier of goods/services within 180 days from the date of invoice. If payment not made, the ITC amount claimed will be added to the output liability of the month in which such 180 days period gets completed. (include. Interest & Penalty) However, upon payment to the supplier, the amount of ITC can be reclaimed for the month in which such payment to supplier takes place. Eg. If output liability current month = 1 Lac & ITC worth Rs. 10,000 /- not paid for more than 180days. So tax to be paid Rs. 1,10,000/- DUE DATE OF INVOICE Invoice or Debit Note should not be received after - The due date of filing of Return of September of next financial year OR - Filing annual return i.e 31 st dec Whichever is later 7

8 APPORTIONMENT OF CREDITS 8

9 APPORTIONMENT OF CREDITS SEC. 17(1) ITC RESTRICTIONS Proportionate credits : ITC based on usage in business Use of ITC For Business Purpose For Non - Business Purposes ITC Available ITC NOT Available Attribution of ITC to be made as per the manner prescribed in the notification to be issued by the Government. 9

10 APPORTIONMENT OF CREDITS Sec. 17 (2) Proportionate credits : ITC based on use of Inputs USE of ITC Partly for Taxable supplies (leviable to tax under this act) Zero rated Supplies (Export, supply to SEZ developer or SEZ unit) Non - taxable Supplies (not taxable under this act.. Eg. Liquor) Exempt Supplies Sec. 2(47) -NIL, nontaxable, wholly or partly exempt Nil - Rated supplies ITC Available ITC not Available 10

11 APPORTIONMENT OF CREDITS SEC.17(2) : Rule 7 - EXAMPLE Sr. No. PARTICULARS Reference CGST SGST/ UTGST 1 Total input tax on inputs and input services for the tax period May 2018 Out of Total Input Tax (T) : 2 2 Input tax used exclusively for non-business purposes (Note 1) 3 Input tax used exclusively for effecting exempt supplies (Note 1) 4 Input tax ineligible under Sec. 17(5) IGST T 1,00,000 1,00,000 50,000 T1 10,000 10,000 5,000 T2 10,000 10,000 5,000 T3 5,000 5,000 2,500 Total 25,000 25,000 12,500 5 ITC credited to Electronic Credit Ledger (Note 1) C1 = T (T1+T2+T3) 1,00, = 75,000 75,000 37,500 11

12 Sr. No APPORTIONMENT OF CREDITS SEC.17(2) : Contd Rule 7 - EXAMPLE PARTICULARS Reference CGST SGST/ UTGST 6 Input tax credit used exclusively for taxable supplies (including zero rated supplies) IGST T4 50,000 50,000 25,000 7 Common credit C2 = C1 - T4 25,000 25,000 12,500 8 Aggregate value of exempt supplies for the tax period May 2018 (Note 2 & 3) 9 Total Turnover of the registered person for the tax period May 2018 (Note 2) 10 Credit attributable to exempt supplies 11 Credit attributable to non business Purposes 12 Net eligible common credit C3 = C2 (D1 + D2) 13 Total credit eligible (Exclusive + Common) E 25,00,000 25,00,000 25,00,000 F 1,00,00,000 1,00,00,000 1,00,00,000 D1 =(E/F)*C2 6,250 6,250 3,125 D2 = C2 * 5% 1,250 1, ,500 17,500 8,750 G = T4 + C3 67,500 67,500 33,750 12

13 APPORTIONMENT OF CREDITS SEC.17(2) : Contd Rule 7 - EXAMPLE Note 1 T1, T2, T3 and T4 shall be DETERMINED AS ABOVE and declared in Form GSTR-2 Note 2 If the registered person does not have any turnover for May 2018, then the value of E and F shall be considered for the last tax period for which such details are available Note 3 Aggregate value excludes taxes Note 4 The registered person is expected to make such computation for each tax period and for the whole year as well. Note 4 In case the resultant computation results in short credit availed, then such credit can be claimed in the electronic credit ledger. Note 4 Further, if on computation for the whole year, the registered person has claimed excess credit on a month on month basis, then such excess credit claimed for the year shall be added back to the output liability and will be liable for payment with interest. 13

14 INELIGIBLE ITC BLOCKED CREDITS- SEC

15 INELIGIBLE ITC (BLOCKED CREDITS) SEC.17(5)(a) (a) MOTOR VEHICLES ITC for Motor Vehicles will not be available Except when they are used for Transportation of Goods, or Making the following taxable services: I. Further supply of such vehicles/conveyances, or II. Transportation of passengers, or III. Training for driving/flying/navigating such vehicles/conveyances. 15

16 INELIGIBLE ITC (BLOCKED CREDITS) SEC.17(5)(b) (b) Supply of goods and services being: Foods & Beverages Outdoor catering Beauty Treatment Health Services Cosmetic & Plastic Surgery Allowed only if goods or services or both of a particular category are used towards making taxable outward supplies of the same category as an element of a taxable composite or mixed supply. 16

17 INELIGIBLE ITC (BLOCKED CREDITS) SEC.17 (c) Supply of goods and services being: Life / Rent-a-cab Health Insurance Allowed only if where the services are notified as obligatory for an employer to provide an employee. Membership of club Health & Fitness Centre Travel benefits to employee Never Allowed 17

18 INELIGIBLE ITC (BLOCKED CREDITS) SEC.17 (d) Construction of immovable property (other than P & M) Works contract services except where it is an input service for further supply of works contract service. Eg. ABC builders employs L & T contractor for constructing the appartment ITC allowed Goods or Services received by a taxable person for construction of an immovable property on his own account even when used in the course or furtherance of business Eg. Construction of showroom building ITC Not Available * Construction - includes re-construction, renovation, additions or alterations or repairs, to the extent of capitalization, to the said immovable property. Please note that alterations and repairs are also included in this definition. 18

19 INELIGIBLE ITC (BLOCKED CREDITS) SEC.17 Goods or services or both on which the tax paid under composition scheme Goods or services or both received by a non-resident taxable person except on goods imported by him Goods or services or both used for personal consumption Goods lost, stolen, destroyed, written off or disposed of by way of gift or free samples.. -Eg. Pharma Companies.. Inward supplies on which tax has been paid u/s 74,129 & Tax not paid/short paid -ITC wrongly availed (Fraud, willful misstatement or suppression of facts 19

20 AVAILABILITY OF CREDIT IN SPECIAL CIRCUMSTANCES SEC

21 Eligibility of input tax credit on inputs held in stock and contained in semi finished and finished goods held in stock: Eligibility & Time Limit of ITC Availment Registered Person Only 16(1) Sec.18(1)(a) Person applied for registration within 30 days from the day he become liable to register Admissible to take ITC ITC available in respect of a) Inputs b) Semifinished goods c) Finished Goods ITC Amount will be credited to the Electronic credit ledger On the day immediately preceding the date from which be becomes liable to pay tax 21

22 Eligibility of input tax credit on inputs held in stock and contained in semi finished and finished goods held in stock: Eligibility & Time Limit of ITC Availment Sec. 18(1)(b) Person Applied for Voluntary Registration Sec.18(1)(c) Registered person ceases to pay tax under composition scheme ITC available in respect of a) Inputs b) Semi-finished goods c) Finished Goods ITC available in respect of a) Inputs b) Semi-finished goods c) Finished Goods d) Capital Goods On the day immediately preceding the date of grant of Registration On the day immediately preceding the date from which be becomes liable to pay tax 22

23 Eligibility of input tax credit on inputs held in stock and contained in semi finished and finished goods held in stock: Eligibility & Time Limit of ITC Availment Sec. 18(1)(d) Exempt supply becomes taxable supply of (G/S/both) ITC available in respect of a) Inputs b) Semi-finished goods c) Finished Goods d) Capital Goods On the day immediately preceding the date from which such supply becomes taxable. Sec. 18 (3) Change in Constitution of Registered Person On account of : - Sale - Merger - Demerger - Amalgamation - Lease, or - Transfer of business As per Rule- 6 of ITC Rules : Furnish details in Form GST ITC - 02 Transfer of unutilized ITC in the electronic credit ledger to such - Sale, Merger, Demerger, Amalgamation, Lease, or Transfer of business 23

24 AVAILABILITY OF CREDIT IN SPECIAL CIRCUMSTANCES SEC. 18 EXAMPLES : Sec. 18(1)(a) Person Liable to pay tax A person becomes liable to pay tax on 1st August Eg. T/o exceeds 20 lacs.. and has obtained registration on 15th August Such person is eligible for input tax credit on inputs held in stock as on 31st July Sec. 18(1)(b) Voluntary Registration Mr. A applies for voluntary registration on 5th June 2017 and obtained registration on 22th June Mr. A is eligible for input tax credit on inputs in stock as on 21st June Sec. 18(1)(c) Composition to Normal Scheme Mr. B, registered person was paying tax under composition rate up to 30th July However, w.e.f 31st July Mr. B becomes liable to pay tax under regular scheme.. (T/o exceeds 75 lacs) - Mr. B is eligible for input tax credit on inputs held in stock as on closure of business hours as on 30th July

25 AVAILABILITY OF CREDIT IN SPECIAL CIRCUMSTANCES CONDITIONS: SEC.18: (Rule 5) Declaration in FORM GST ITC 1 must be filed.. (monthly job) within thirty (30) days from the date of becoming eligible to ITC To be certified by CA / CWA if ITC > Rs. 2 Lakhs Rule 5 - declaration to be filed containing details of stocks and capital goods along with a certificate from CA [ Sec.18(1)(a)(b)(c)(d) ] The supplier will not be entitled to credit of goods and or services or both after expiry of 1 year from date of tax invoice (eg. Service can be first & bill later..) The credit on capital goods shall be reduced by 5% per quarter or part thereof from the date of invoice (called as Factoring Method) Such credits are subject to verification of details furnished by the supplier in GSTR 1 or GSTR 4 on the common portal.

26 1.EXEMPT TO TAXABLE CASE SEC.18 : EXAMPLE (RULE 5) Illustration (Rule 5): ABC Steels Limited is a manufacturer of iron & steel. It procures raw materials and inputs such as iron ore, chemicals, gases, etc. and capital goods including plant & machinery, for the manufacture of such iron & steel. In this example, it has been assumed that iron & steel (which is the outward supply of ABC Steels Ltd) is exempt from payment of taxes until 31- Mar Iron & steel become taxable with effect from 01-Apr The method of availment of input tax credits on inputs contained in stock and capital goods as on 31-Mar-2020 is covered by this illustration 26

27 1. EXEMPT TO TAXABLE CASE SEC.18 : EXAMPLE Que.(RULE 5) PARTICULARS (For Inputs) Amount 1. Value of inputs in stock on 31-Mar ,00,000 18,000 All inputs were procured after 01-Jul Value of inputs contained in semi-finished goods held in stock on 31-Mar ,00,000 6% 24,000 6% 24,000 All inputs contained in semi finished goods were procured after 01-May Value of inputs contained in finished goods held in stock on 31-Mar ,000 6% 3,000 6% 3,000 Only inputs worth Rs.40,000 in finished goods were procured after 01-Apr

28 EXEMPT TO TAXABLE CASE SEC.18 : EXAMPLE Ans.(RULE 5) PARTICULARS 1. IGST credits on inputs on stock held on ITC on the value of inputs: All inputs were acquired within 1 year prior to the effective date on which the goods become taxable. Hence, entire ITC would be allowed. (All inputs were procured after 01-Jul-2019) 2. CGST credits on inputs in stock held on AMOUNT 18,000 ITC on the value of inputs contained in semi-finished goods: - All inputs were acquired within 1 year prior to the effective date on which the goods become taxable. Hence, entire ITC would be allowed. CGST credits on inputs in stock held on ITC on the value of inputs contained in finished goods: Out of the total stock of Rs. 50,000/-, inputs totalling to Rs. 10,000/- are older than 1 year from the effective date on which the goods become taxable. Therefore, ITC to this extent stands disallowed. ITC on inputs contained in stock of Rs. 40,000 would be eligible. [Eligible credit = 40,000 * 6%] 24,000 2,400 CGST Credits available on inputs 26,400 28

29 EXEMPT TO TAXABLE CASE SEC.18 : EXAMPLE Ans.(RULE 5) PARTICULARS AMOUNT 2. SGST credits on inputs in stock held on ITC on the value of inputs contained in semi-finished goods: - Same as CGST SGST credits on inputs in stock held on ITC on the value of inputs contained in finished goods: - Same as CGST 24,000 2,400 SGST Credits available on inputs 26,400 Therefore total Credits available on Inputs : CGST 26,400 SGST 26,400 IGST 18,000 70,800 29

30 EXEMPT TO TAXABLE CASE SEC.18 : EXAMPLE Que.(RULE 5) PARTICULARS (For Capital Goods) Date of invoice of capital goods Date from which the exempt goods become taxable No. of quarters from date of invoice 1 Percentage points to be reduced (5% per quarter) 5% Amount IGST paid on the capital goods used exclusively in relation to goods exempted up to 31-Mar ,60,000 ITC to be reduced by 5% on 3,60,000 (18,000) 3,42,000 Rule 5(1)(a) of the Input Tax Credit Rules provides that input tax credit on capital goods can be claimed after reducing 5% per quarter of a year or part thereof, from the date of invoice in respect of which capital goods are received. - Therefore, the number of quarters is 1, being the first quarter of the year The reversal of credit would therefore be, to the extent of 5% of the IGST credit of Rs.3,60,000, - i.e. IGST credit on capital goods would stand reduced to the extent of Rs.18,

31 2.REVERSAL OF CREDITS SEC.18 (4): (RULE 9) ITC RULES, 2017 Credit has to be reversed in respect of inputs & capital goods lying in stock COMPOSITION SCHEME U/S 10 Balance ITC if any in electronic credit ledger shall be lapsed CANCELLATION OF REGISTRATION U/S 29 (5) FROM REGULAR REGISTRATION TO EXEMPTION BY WAY OF NOTIFICATION 31

32 2.REVERSAL OF CREDITS SEC.18 (4): (RULE 9) ITC RULES, 2017 For inputs held in stock and inputs contained in semi-finished and finished goods held in stock, the ITC shall be calculated proportionately on the basis of corresponding invoices on which credit had been availed by the registered taxable person on such input; For capital goods held in stock the ITC involved in the remaining useful life in months shall be computed on pro-rata basis, taking the useful life as 5 years. Where the tax invoices related to the inputs held in stock are not available, the registered person shall estimate the amount under sub-rule (1) based on the prevailing market price of goods The amount determined shall form part of the output tax liability of the registered person and the details of the amount shall be furnished in FORM GST ITC-03, where such amount relates to any event specified Sec. 18(4) The details furnished in shall be duly certified by a practicing chartered accountant or cost accountant. 32

33 SHIFTING TO COMPOSITION SCHEME SEC.18 : EXAMPLE 1 WHERE ITC LAPSES (RULE 9) Sr. No. PARTICULARS REFERENCE AMOUNT 1 Value of Capital goods 1,00,000 12% A 12,000 Invoice Value 1,12,000 2 Date of Shift to composition scheme (can be opted in F.Y. beginning) Date of inward supply and use of capital goods Given Period of use (days) from to Period of use (months) 19 5 Residual life in months (Considering full life as 5 years) 6 ITC attributable to residual life (TO BE ADDED TO THE OUTPUT TAX LIABILITY OF THE REFISTERED PERSON) B 41 C=(A*B/60) C= 12,000*41/60 8,200 7 Balance of ITC as on Given 10,000 8 ITC utilized for capital goods for residual life 8,200 9 Balance ITC will lapse 1,800 33

34 2. SHIFTING TO COMPOSITION SCHEME SEC.18 : EXAMPLE 2 WHERE ITC BECOMES PAYABLE (RULE 9) Sr. No. PARTICULARS REFERENCE AMOUNT 1 Value of Capital goods 1,00,000 12% A 12,000 Invoice Value 1,12,000 2 Date of Shift to composition scheme Date of inward supply and use of capital goods Given Period of use (days) from to Period of use (months) 19 5 Residual life in months (Considering full life as 5 years) 6 ITC attributable to residual life (TO BE ADDED TO THE OUTPUT TAX LIABILITY OF THE REFISTERED PERSON) B 41 C=(A*B/60) C= 12,000*41/60 8,200 7 Balance of ITC as on Given 1,500 8 ITC utilized for capital goods for residual life 8,200 9 Balance Tax Payable 6,700 34

35 2. SHIFTING TO COMPOSITION SCHEME SEC.18 : EXAMPLE 3 WHERE NO PAYMENT IS REQUIRED (RULE 9) Sr. No. PARTICULARS REFERENCE AMOUNT 1 Value of Capital goods 1,00,000 12% A 12,000 Invoice Value 1,12,000 2 Date of Shift to composition scheme Date of inward supply and use of capital goods Given Period of use (months) from to Period of use ( years) 5 Residual life in months (Considering full life as 5 years) 5 years & 7 months B - 6 ITC attributable to residual life C = (A*B/60) 0 7 NO PAYMENT REQUIRED

36 ITC IN CASE OF INPUTS & CAPITAL GOODS SENT FOR JOB WORK SEC

37 JOB WORK PROCEDURE : SEC. 143 Export Export Supply without payment of tax Supply without payment of tax PRINCIPAL Supply of inputs / capital goods without payment of tax Job Worker - 1 Supply of inputs / capital goods without payment of tax Job Worker 2 Supply of goods on payment of tax Supply of goods on payment of tax Customer Customer Principal must receive back inputs & capital goods (except moulds & dies, jigs & fixtures or tools) within 1 year & 3 year respectively 37

38 ENTITLEMENT OF CREDIT ON INPUTS & CAPITAL GOODS CONDITIONS : Rule 10 To maintain paper trail of transaction If non-receipt within prescribed period 1 year or 3 years Issue Delivery Challan Deemed Invoice Challan must contain all details Report in GSTR -1 All 9 points as required in Invoice rules All issued & received back details of challans The credit of inputs can be taken even if inputs are sent directly to jobworker s premises without bringing it to principal s place of business. 38

39 MANNER OF DISTRBUTION OF CREDIT BY INPUT SERVICE DISTRIBUTOR (ISD) SEC

40 MANNER OF DISTRBUTION OF CREDIT BY INPUT SERVICE DISTRIBUTOR (ISD) SEC. 20 Input Service Distributor (ISD) is an office of the supplier of goods or services or both - Only to other units of the same person (i.e same PAN) - where a document (like invoice) of services attributable to other locations are received (since they might be registered separately). - Since the services relate to other locations the corresponding credit should be transferred to such locations (having separate registrations) as services are supplied from there. 40

41 CONDITIONS TO BE FULFILLED BY ISD FOR DISTRIBUTING ITC The credit can be distributed to recipients of credit against a document called ISD Invoice as per Invoice Rule -7 clearly indicating that it is issued only for distribution of ITC Credit distributed should not exceed the credit available for distribution. Tax paid on input services used by a particular location (registered as supplier), to be distributed only to that location. Credit of tax paid on input service used by more than one location who are operational is to be distributed to all of them based on the pro rata basis of turnover of each locations in a State to aggregate turnover of all such locations who have used such services. 41

42 MANNER OF DISTRBUTION OF CREDIT BY INPUT SERVICE DISTRIBUTOR (ISD) SEC. 20 ISD & recipient in DIFFERENT States ISD & recipient in SAME State (Business Vertical) CGST Act SGST Act CGST Act SGST Act Credit of CGST or IGST as IGST Credit of SGST as IGST Credit of CGST or IGST as CGST Credit of SGST or IGST as SGST 42

43 EXAMPLE RULE 4 : ITC RULES ABC Infotech Ltd. has its head office in Mumbai, for which it additionally has an ISD registration. The company has 12 units across India including its head office. All taxes have been considered at 18% (CGST and SGST at 9% each). The turnover of each of the units during the year is: Mumbai: 1 crore; Bangalore 2 crore; Kolkata 1 crore; Gurgaon 2 crore; each of the other 8 units: 50 lakhs, resulting in the aggregate turnover of the company in the previous financial year, of 10 crores. It receives the following invoices in the name of the ISD at Mumbai, for the month of January 2018: 43

44 EXAMPLE RULE 4 : ITC RULES Invoice A: Rs. IGST 18,000 issued by Peace Link Technologies (registered in Uttar Pradesh) for repairs executed in 2 units Bangalore, Kolkata, Gurgaon (Note:Gurgaon location is not registered as it is engaged in making only exempt supplies); Particulars Invoice Bangalore Kolkata Mumbai Gurgaon 8 units Total T/o in state(given) Pro rata basis 2 Crore 1 Crore Crore Crore 40% 20% % % Credit 18,000 7,200 3, , ,000 Type IGST IGST IGST --- IGST

45 EXAMPLE RULE 4 : ITC RULES Invoice B: Rs. CGST 27,000, SGST 27,000 issued by M/s. Tec Force (registered in Pune) for repairs executed in 3 units - Mumbai, Bangalore, Kolkata; Particulars Invoice Bangalore Kolkata Mumbai Gurgaon 8 units Total T/o in state 2 Crore 1 Crore 1 Crore Crore Pro rata basis CGST Credit % 25% 25% % *Distribution 13,500 6,750 6, ,000 Type CGST IGST IGST CGST SGST Credit *Distribution 13,500 6,750 6, ,000 Type SGST IGST IGST SGST

46 EXAMPLE RULE 4 : ITC RULES Invoice C: Rs. IGST 90,000 issued by M/s.G Marketing (registered in Bangalore) for marketing services for the company as a whole; Particulars Invoice Bangalore Kolkata Mumbai Gurgaon 8 units Total T/o in state Pro rata basis 2 Crore 1 Crore 1 Crore 2 Crore 0.5*8 Crore 20% 10% 10% 20% 5% * 8 units 10 Crore 100% Credit 90,000 18,000 9,000 9,000 18,000 4,500*8 units 90,000 Type IGST IGST IGST IGST IGST IGST 46

47 MANNER OF RECOVERY OF CREDIT DISTRIBUTED IN EXCESS BY ISD SEC.21 47

48 MANNER OF RECOVERY OF CREDIT DISTRIBUTED IN EXCESS BY ISD Excess Credit Distributed by ISD Credit distributed in excess of what was available Excess credit distributed to one or more Recipient of credit Recovery of such excess credit with interest from the recipient of credit. 48

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