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An 18% with-ITC restaurant on Zomato, Swiggy, and Magicpin pays 18% GST on aggregator commission and is entitled to claim the input tax credit, but the credit is conditional on the aggregator filing GSTR-1 correctly, the invoice appearing in GSTR-2B with the right GSTIN, and credit notes for cancelled orders being tracked back to the original commission invoice — three preconditions that fail silently and leak ITC every month.
Pull the aggregator settlement file commission line by order, match each commission against the aggregator's monthly tax invoice, locate that invoice in the restaurant's GSTR-2B under the aggregator's GSTIN, post the input GST to claimable ITC only if the 2B entry exists, defer the claim to the next month if the entry is missing, and reverse ITC against any credit notes that flow in for cancelled orders.
Aggregator settlement file connector with commission and GST line parsing; aggregator GSTIN master per state of operation; GSTR-2B fetch and inward-supply matcher keyed to aggregator GSTIN and invoice number; Rule 36(4) eligibility filter that defers ITC claim until 2B entry appears; credit-note reconciliation logic for cancelled orders.
A monthly GSTR-3B that claims 18% ITC on aggregator commission only when the entry is in GSTR-2B, defers any missing entries to the next cycle without breaching Rule 36(4), reverses ITC for cancelled orders via credit notes, and produces a four-way reconciled audit trail across settlement file, aggregator invoice, GSTR-2B, and purchase register.
A restaurant group in Pune lists 8 outlets across Maharashtra on Zomato, Swiggy, and Magicpin. Each aggregator charges commission at 18% to 30% of net order value, with 18% GST on top. The monthly aggregator commission across all three platforms runs to ₹14 lakh, and the GST on that commission — roughly ₹2.5 lakh — is fully claimable input tax credit because the group operates in the 18% with-ITC regime. The catch: in any given month, 5% to 12% of that ₹2.5 lakh either fails to appear in GSTR-2B, appears under the wrong GSTIN, or gets reversed by an unmatched credit note. This article is for finance teams reconciling aggregator commission ITC against GSTR-2B at scale.
What Restaurant GSTR-2B Commission ITC Reconciliation Involves
Restaurant GSTR-2B commission ITC reconciliation is the process of matching four data sets each month: the aggregator settlement file (order-level commission with GST breakup), the aggregator’s consolidated tax invoice for commission, the restaurant’s GSTR-2B (inward supplies under the aggregator’s GSTIN), and the restaurant’s purchase register (commission expense, input GST, and payable settlement). The output is a GSTR-3B in which every rupee of input tax credit on commission is backed by a 2B entry that survives Rule 36(4).
The complication unique to India is that ITC is not claimable merely on possession of an invoice. Under Rule 36(4) of the CGST Rules, the credit is conditional on the aggregator having filed GSTR-1 for the period and the entry having flowed into the restaurant’s GSTR-2B. An invoice held but not reflected in 2B is not claimable, and any provisional claim is a Rule 36(4) breach reversible with interest under Section 50.
How the Commission ITC Flow Works
The Aggregator Issues a Tax Invoice
Zomato, Swiggy, and Magicpin each generate a monthly consolidated tax invoice for commission earned across all orders facilitated for the restaurant. The invoice carries the aggregator’s GSTIN, the restaurant’s GSTIN, the aggregator’s commission gross, and 18% GST. This is an inward supply to the restaurant — the aggregator is the supplier of commission services, and the restaurant is the recipient.
The Invoice Flows into GSTR-2B
When the aggregator files GSTR-1 by the 11th of the following month, the commission invoice flows into the restaurant’s GSTR-2B for that period. GSTR-2B is generated on the 14th of each month and is the single source of truth for ITC eligibility under Rule 36(4). The restaurant’s input tax credit on the 18% GST is claimable in GSTR-3B for the month in which the entry appears in 2B.
Cancelled Orders Trigger Credit Notes
When an order is cancelled, the commission accrued on that order is reversed. The aggregator issues a credit note in the same or subsequent month. The credit note flows into the restaurant’s GSTR-2B as a negative entry under the aggregator’s GSTIN. The restaurant’s GSTR-3B ITC must be reduced by the same amount in the period the credit note appears. Tracking credit notes back to the original commission invoice is the single largest reconciliation discipline in this workflow.
Aggregator Commission ITC Reconciliation Reference
| Reconciliation Step | Source Data | Failure Mode |
|---|---|---|
| Match settlement commission to aggregator invoice | Settlement file vs aggregator monthly invoice | Aggregator commission rate change mid-cycle |
| Match aggregator invoice to GSTR-2B entry | Aggregator invoice vs GSTR-2B inward supplies | Aggregator filed GSTR-1 against wrong GSTIN |
| Apply Rule 36(4) eligibility filter | GSTR-2B presence | Entry missing because aggregator filed late |
| Reconcile credit notes against original invoices | GSTR-2B credit-note entries | Unmatched credit notes inflate net ITC |
| Post claimable ITC to GSTR-3B | Eligible 2B entries | Provisional claim without 2B entry — Rule 36(4) breach |
India Compliance Angle: Rule 36(4) and Multi-State GSTIN Discipline
Rule 36(4) of the CGST Rules is unchanged by the new Income Tax Act 2025 and remains in force exactly as before. The rule limits ITC strictly to invoices that have flowed into GSTR-2B. For an 18% with-ITC restaurant on aggregators, this means commission ITC is locked to the 2B cycle, not to the invoice receipt cycle. A restaurant that holds the aggregator invoice on the 5th of the month but sees the entry only in next month’s 2B must defer the claim — claiming it in the current GSTR-3B is a Rule 36(4) breach reversible with interest. Multi-state operators face an additional discipline: the aggregator must file GSTR-1 against the correct state-wise GSTIN of the restaurant, and master-data drift between aggregator records and restaurant filings is a recurring cause of missing 2B entries. For broader rate-regime context, see restaurant GST reconciliation 5% vs 18% which covers when the ITC stream is claimable in the first place.
Multi-outlet restaurant groups using GST reconciliation software automate the four-way match between settlement file, aggregator invoice, GSTR-2B, and purchase register, with Rule 36(4) eligibility filters that defer claims for missing 2B entries rather than booking them provisionally. Reconciliation software India extends the same pipeline across multiple aggregators, multiple GSTINs, and credit-note tracking at order-level granularity. The GST Portal generates GSTR-2B on the 14th of each month and publishes the Rule 36(4) framework that governs commission ITC claimability. For the underlying settlement file mechanics, see Zomato restaurant settlement reconciliation, and for the pillar overview see restaurant reconciliation India.
For the restaurant chain industry surface, see the Restaurant Chains industry guide. For the buying-intent surface covering this rail, see the restaurant reconciliation software for India overview, and for a head-to-head against the aggregator-side reconciliation tool category, see TransactIG vs Cointab.
The questions below address the most common commission ITC reconciliation issues raised by Indian restaurant finance teams.