Rule 37/37A: ITC Reversal/Reclaim Reporting in GSTR-9

Rule 37 and Rule 37A of the CGST Rules represent unique provisions in GST law that govern ITC reversal and reclaim. Unlike other reasons for ITC reversal, where timing and original financial year matter significantly, Rule 37 and Rule 37A follow a fundamentally different principle: reclaimed ITC is always treated as ITC of the year in which the reclaim occurs, regardless of when the original invoice was issued.

This distinctive treatment creates special reporting requirements in GSTR-9 that differ dramatically from other ITC scenarios. Misunderstanding these rules causes significant errors in annual return filing, particularly when transactions span multiple financial years. This blog post clarifies the exact treatment of Rule 37 and Rule 37A reversals and reclaims, with detailed examples across various timing scenarios.

Understanding Rule 37: The 180-Day Payment Rule

Rule 37 of the CGST Rules mandates that if you don’t pay your supplier within 180 days from the invoice date, you must reverse the ITC you claimed on that purchase.

The Basic Mechanism

Step 1 – Claim: You receive an invoice and claim ITC
Step 2 – Monitor: Track whether payment is made within 180 days
Step 3 – Reverse: If no payment by 180th day, reverse the ITC in your next GSTR-3B (Table 4B2)
Step 4 – Reclaim: When you eventually make payment, reclaim the ITC (Table 4A5 of GSTR-3B)

The Key Provision: No Time Limit for Reclaim

Unlike Section 16(4) which imposes strict time limits for claiming ITC (by November 30 of next FY or annual return filing), Rule 37 reclaims have no such time restriction. You can reclaim the ITC whenever you make the payment, even years later.

This unlimited reclaim window is why Rule 37 ITC receives special treatment in annual returns.

Understanding Rule 37A: The Ineligible Person Rule

Rule 37A deals with situations where the supplier is found to be ineligible to collect GST, either because their registration was cancelled retrospectively or they were never eligible to be registered.

When Rule 37A Applies

Typical scenarios include:

• Supplier’s registration cancelled with retrospective effect
• Supplier found to be a dummy or non-existent entity
• Supplier was engaged in fraudulent transactions
• Department orders reversal of ITC

The Reversal and Reclaim Process

Reversal: When authorities determine the supplier was ineligible, you must reverse the ITC claimed (reported in Table 4B2 of GSTR-3B)

Reclaim: If the issue is later resolved (registration restored, supplier legitimacy established), you can reclaim the ITC

Like Rule 37, Rule 37A reclaims have no specified time limit and follow the same special treatment principles.

The Fundamental Principle: ITC of the Reclaim Year

Here’s the core concept that distinguishes Rule 37/37A from all other ITC scenarios:

Standard ITC Treatment (Non-Rule 37/37A)

ITC is considered to belong to the financial year of the invoice, regardless of when you claim it (subject to time limits).

Example: Invoice dated March 2024 (FY 2023-24) claimed in May 2024 (FY 2024-25) is still considered FY 2023-24 ITC. It goes in Table 6A1 of GSTR-9 for FY 2024-25.

Rule 37/37A ITC Treatment (The Exception)

Reclaimed ITC under Rule 37 or Rule 37A is considered to belong to the financial year in which the reclaim occurs, completely disconnected from the original invoice year.

Example: Invoice dated March 2024 (FY 2023-24), originally claimed in April 2023, reversed in October 2023 due to Rule 37, and reclaimed in May 2025 (FY 2025-26). This reclaimed ITC is treated as FY 2025-26 ITC, not FY 2023-24 ITC.

Why This Distinction Matters

This treatment ensures that:

1. Reclaimed ITC appears in the correct financial year’s net ITC calculations
2. No time-limit restrictions apply (unlike Section 16(4))
3. Annual return reconciliation remains accurate across multiple years
4. The unlimited reclaim window doesn’t create reporting ambiguities

Reporting Rule 37 Reversals: Table 7A

When you reverse ITC due to Rule 37 (non-payment within 180 days), report it in Table 7A of GSTR-9 for the financial year in which you made the reversal.

What Goes in Table 7A

Only reversals made during FY 2024-25 are reported in Table 7A of GSTR-9 for FY 2024-25, regardless of:

• When the original invoice was dated
• When you originally claimed the ITC
• Which FY the invoice pertains to

Example: Within-Year Reversal

Timeline:

• April 2024: Received invoice, claimed ₹1,00,000 ITC
• October 2024: 180 days elapsed without payment, reversed ₹1,00,000 ITC

GSTR-9 Reporting for FY 2024-25:

• Table 6B: ₹1,00,000 (original claim)
• Table 7A: ₹1,00,000 (Rule 37 reversal)

Example: Cross-Year Reversal

Timeline:

• January 2024 (FY 2023-24): Received invoice, claimed ₹50,000 ITC
• August 2024 (FY 2024-25): 180 days elapsed (from January 2024), reversed ₹50,000 ITC

GSTR-9 Reporting for FY 2024-25:

• Table 6A1: ₹0 (this is Rule 37 reversal, special treatment)
• Table 6B to 6H: Nothing (no claim in FY 2024-25)
• Table 7A: ₹50,000 (reversal made in FY 2024-25)

Important: Even though the invoice was from FY 2023-24, the reversal appears in Table 7A of FY 2024-25 because that’s when the reversal action occurred.

Reporting Rule 37A Reversals: Table 7A1

Table 7A1 is specifically for Rule 37A reversals and functions identically to Table 7A in terms of reporting logic.

What Goes in Table 7A1

Reversals due to supplier ineligibility (Rule 37A) made during FY 2024-25 are reported in Table 7A1 of GSTR-9 for FY 2024-25.

Example: Supplier Registration Cancelled

Timeline:

• Throughout FY 2023-24: Claimed ₹5,00,000 ITC from Supplier X
• June 2024: Department cancels Supplier X’s registration with retrospective effect from April 2023
• July 2024: You reverse all ₹5,00,000 ITC in your July 2024 GSTR-3B

GSTR-9 Reporting for FY 2024-25:

• Table 7A1: ₹5,00,000 (Rule 37A reversal)

Note: This doesn’t appear anywhere in your FY 2023-24 GSTR-9 because the reversal action occurred in FY 2024-25.

Reporting Rule 37/37A Reclaims: Always Table 6H

The reclaim of ITC previously reversed under Rule 37 or Rule 37A is always reported in Table 6H of GSTR-9 for the financial year in which the reclaim occurs.

The Golden Rule for Table 6H

Report in Table 6H when:

• ITC was previously reversed (for any reason, in any FY)
• Now being reclaimed in FY 2024-25
• Reason for reclaim is Rule 37 (payment finally made) or Rule 37A (supplier status restored)

The critical distinction: Whether the original invoice was from FY 2024-25, FY 2023-24, or any earlier year is completely irrelevant. Rule 37/37A reclaims are always ITC of the reclaim year.

Example 1: Same-FY Reversal and Reclaim

Timeline:

• April 2024: Claimed ₹1,00,000 ITC
• October 2024: Reversed ₹1,00,000 (Rule 37 – no payment)
• March 2025: Made payment, reclaimed ₹1,00,000

GSTR-9 Reporting for FY 2024-25:

• Table 6A: ₹2,00,000 (claim + reclaim both appear)
• Table 6A1: ₹0 (invoice is from current FY, not preceding FY)
• Table 6A2: ₹2,00,000
• Table 6B: ₹1,00,000 (original claim)
• Table 6H: ₹1,00,000 (reclaim)
• Table 6I: ₹2,00,000 (sum of 6B to 6H)
• Table 6J: ₹0 (perfect match: 6I = 6A2)
• Table 7A: ₹1,00,000 (Rule 37 reversal)

Example 2: Reversal in FY 2024-25, Reclaim in FY 2025-26

Timeline:

• April 2024: Claimed ₹1,00,000 ITC (invoice dated April 2024)
• October 2024: Reversed ₹1,00,000 (Rule 37)
• April 2025: Made payment, reclaimed ₹1,00,000

GSTR-9 Reporting for FY 2024-25:

• Table 6B: ₹1,00,000 (original claim)
• Table 6H: ₹0 (reclaim hasn’t happened in this FY)
• Table 7A: ₹1,00,000 (Rule 37 reversal)
• Table 13: ₹0 (Rule 37 reclaims NOT reported in Table 13)

GSTR-9 Reporting for FY 2025-26:

• Table 6A: Will include the ₹1,00,000 reclaim
• Table 6A1: ₹0 (NOT reported here – Rule 37 exception)
• Table 6H: ₹1,00,000 (reclaim treated as FY 2025-26 ITC)

Critical Point: The reclaim does NOT go in Table 6A1 of FY 2025-26 even though the original invoice was from FY 2024-25. Rule 37 reclaims are exempt from the 6A1 reporting requirement.

Example 3: Reversal in FY 2023-24, Reclaim in FY 2024-25

Timeline:

• January 2024 (FY 2023-24): Claimed ₹50,000 ITC
• August 2024 (FY 2024-25): Reversed ₹50,000 (Rule 37 – 180 days from January 2024)
• December 2024 (FY 2024-25): Made payment, reclaimed ₹50,000

GSTR-9 Reporting for FY 2024-25:

• Table 6A: ₹50,000 (only the reclaim; original claim was in previous FY)
• Table 6A1: ₹0 (NOT reported here – Rule 37 exception)
• Table 6A2: ₹50,000
• Table 6H: ₹50,000 (reclaim)
• Table 6I: ₹50,000
• Table 6J: ₹0 (perfect match)
• Table 7A: ₹50,000 (reversal made in this FY)

Note: Both the reversal (August 2024) and reclaim (December 2024) happened in FY 2024-25, so both appear in Tables 7A and 6H of the same GSTR-9.

The Table 6A1 Exclusion: Why It Matters

One of the most important aspects of Rule 37/37A treatment is the explicit exclusion from Table 6A1.

What Table 6A1 Normally Captures

Table 6A1 is designed to capture ITC of preceding FY (2023-24) that you claimed in current FY (2024-25) for reasons other than Rule 37/37A. This includes:

• Missed ITC you claim within the November 30, 2024 deadline
• ITC reversed and reclaimed for reasons like non-receipt of goods (Circular 170/02/2022-GST)
• Late supplier filings where you claim ITC in the current FY

The Rule 37/37A Exception

Do NOT report in Table 6A1:

• ITC pertaining to FY 2023-24 (or any preceding FY)
• That was reversed in any FY
• And reclaimed in FY 2024-25 due to Rule 37 or Rule 37A

Instead, this always goes in Table 6H of FY 2024-25.

Why This Exception Exists

The logic is elegant:

1. Rule 37/37A reclaims have no time limit (unlike Section 16(4))
2. They’re treated as ITC of the reclaim year, not the invoice year
3. Table 6A1 is for preceding-year ITC subject to normal time limits
4. Table 6H accommodates the special treatment by accepting reclaims regardless of original invoice year

Example Illustrating the Difference

Scenario A: Non-Rule 37 Reclaim

• Invoice: March 2024 (FY 2023-24)
• Claimed and reversed: April 2024 (non-receipt of goods)
• Reclaimed: May 2024 (goods received)

Reporting in GSTR-9 for FY 2024-25:

• Table 6A1: ✓ Report here (preceding FY ITC, non-Rule 37 reason)
• Table 6H: ✗ Do NOT report

Scenario B: Rule 37 Reclaim (Same Facts)

• Invoice: March 2024 (FY 2023-24)
• Claimed and reversed: October 2024 (Rule 37 – no payment)
• Reclaimed: May 2025 (payment made)

Reporting in GSTR-9 for FY 2025-26:

• Table 6A1: ✗ Do NOT report (Rule 37 exception)
• Table 6H: ✓ Report here

The Table 13 Exclusion: Another Key Distinction

Table 13 captures “ITC of the financial year availed in the next financial year.” However, Rule 37/37A reclaims follow special rules here too.

What Normally Goes in Table 13

When ITC pertaining to FY 2024-25 is claimed in FY 2025-26 for normal reasons (missed claims, late supplier additions, non-Rule 37/37A reclaims), you report it in Table 13 of GSTR-9 for FY 2024-25.

The Rule 37/37A Exception for Table 13

Do NOT report in Table 13 of FY 2024-25:

• ITC pertaining to FY 2024-25
• That was reversed in FY 2024-25 due to Rule 37/37A
• And reclaimed in FY 2025-26

Reason: Since Rule 37/37A reclaims are treated as ITC of the reclaim year (FY 2025-26), they don’t belong to FY 2024-25 for reporting purposes. They’ll be reported entirely in FY 2025-26 GSTR-9 (in Table 6H).

Example Highlighting Table 13 Treatment

Facts:

• Invoice dated February 2025 (FY 2024-25)
• Claimed in February 2025
• Reversed in February 2025 due to non-receipt of goods (not Rule 37)
• Reclaimed in April 2025

GSTR-9 Reporting for FY 2024-25:

• Table 6B: ₹X (original claim)
• Table 7H: ₹X (other reversal)
• Table 13: ₹X ✓ (this reclaim will happen in next FY)

Same Facts, But Rule 37 Reversal:

• Invoice dated February 2025 (FY 2024-25)
• Claimed in February 2025
• Reversed in October 2024 due to Rule 37
• Reclaimed in April 2025

GSTR-9 Reporting for FY 2024-25:

• Table 6B: ₹X (original claim)
• Table 7A: ₹X (Rule 37 reversal)
• Table 13: ₹0 ✗ (Rule 37 reclaims NOT reported here)

Timing Scenarios: A Complete Matrix

Let’s systematically examine all possible timing combinations for Rule 37/37A:

Scenario 1: Claim, Reverse, and Reclaim All in FY 2024-25

Timeline: All three actions in same FY

GSTR-9 for FY 2024-25:

• Table 6B: Original claim ✓
• Table 6H: Reclaim ✓
• Table 7A/7A1: Reversal ✓
• Table 13: Nothing

Outcome: Everything reported in one annual return. Table 6A shows double (claim + reclaim), but bifurcation in 6B and 6H correctly accounts for both.

Scenario 2: Claim and Reverse in FY 2024-25, Reclaim in FY 2025-26

Timeline: Original and reversal in FY 2024-25; reclaim in FY 2025-26

GSTR-9 for FY 2024-25:

• Table 6B: Original claim ✓
• Table 6H: Nothing
• Table 7A/7A1: Reversal ✓
• Table 13: Nothing (Rule 37 exception)

GSTR-9 for FY 2025-26:

• Table 6H: Reclaim ✓ (treated as FY 2025-26 ITC)
• Table 6A1: Nothing (Rule 37 exception)

Scenario 3: Claim in FY 2023-24, Reverse in FY 2024-25, Reclaim in FY 2024-25

Timeline: Original in FY 2023-24; reversal and reclaim both in FY 2024-25

GSTR-9 for FY 2024-25:

• Table 6H: Reclaim ✓
• Table 7A/7A1: Reversal ✓
• Table 6A1: Nothing (Rule 37 exception)

Note: Original claim was in FY 2023-24 GSTR-9 (in Table 6B of that year).

Scenario 4: Claim in FY 2023-24, Reverse in FY 2023-24, Reclaim in FY 2024-25

Timeline: Original and reversal in FY 2023-24; reclaim in FY 2024-25

GSTR-9 for FY 2023-24:

• Table 6B: Original claim ✓
• Table 7A/7A1: Reversal ✓

GSTR-9 for FY 2024-25:

• Table 6H: Reclaim ✓
• Table 6A1: Nothing (Rule 37 exception)

Scenario 5: Claim in FY 2023-24, Reverse in FY 2024-25, Reclaim in FY 2025-26

Timeline: Each action in different FY

GSTR-9 for FY 2023-24:

• Table 6B: Original claim ✓

GSTR-9 for FY 2024-25:

• Table 7A/7A1: Reversal ✓

GSTR-9 for FY 2025-26:

• Table 6H: Reclaim ✓
• Table 6A1: Nothing (Rule 37 exception)

Scenario 6: Claim in FY 2022-23, Reverse in FY 2023-24, Reclaim in FY 2024-25

Timeline: Multi-year span

GSTR-9 for FY 2022-23:

• Table 6B: Original claim ✓

GSTR-9 for FY 2023-24:

• Table 7A/7A1: Reversal ✓

GSTR-9 for FY 2024-25:

• Table 6H: Reclaim ✓ (still treated as FY 2024-25 ITC)
• Table 6A1: Nothing (Rule 37 exception, regardless of how old the invoice)

Key Insight: No matter how many years pass, Rule 37/37A reclaims are always ITC of the reclaim year.

How Rule 37/37A Differs from Other Reversal Reasons

Understanding what makes Rule 37/37A special requires comparing it to other common reversal scenarios.

Comparison: Rule 37 vs. Non-Receipt of Goods (Circular 170)

Rule 37 (Payment Issue):

• Reversal reason: No payment within 180 days
• Reclaim timing: Unlimited—whenever payment is made
• Reclaim treatment: ITC of reclaim year
• Reporting: Always Table 6H, never Table 6A1

Non-Receipt of Goods:

• Reversal reason: Goods not received (Circular 170/02/2022-GST)
• Reclaim timing: Subject to Section 16(4) time limits
• Reclaim treatment: ITC of original invoice year
• Reporting: Table 6A1 if preceding year, Table 6H if current year reclaim

Example Illustrating the Difference

Both scenarios start identical:

• Invoice dated March 2024 (FY 2023-24)
• Claimed in March 2024
• Reversed in April 2024

Scenario A: Rule 37 Reversal and Reclaim

• Reversed: October 2024 (Rule 37)
• Reclaimed: May 2025

FY 2024-25 GSTR-9:

• Table 7A: Reversal ✓
• Table 6A1: Nothing
• Table 6H: Nothing (reclaim next FY)

FY 2025-26 GSTR-9:

• Table 6H: Reclaim ✓
• Table 6A1: Nothing

Scenario B: Non-Receipt Reversal and Reclaim

• Reversed: April 2024 (goods not received)
• Reclaimed: May 2024 (goods received)

FY 2024-25 GSTR-9:

• Table 7H: Reversal ✓
• Table 6A1: Reclaim ✓ (preceding FY ITC)
• Table 6H: Nothing

The divergence: Same invoice, different reversal reasons lead to completely different reporting: Rule 37 goes to Table 6H of next FY, non-receipt goes to Table 6A1 of current FY.

Multiple Reversals and Reclaims: Complex Scenarios

Sometimes the same ITC undergoes multiple reversal-reclaim cycles. Rule 37/37A treatment remains consistent.

Example: Double Cycle

Timeline:

• April 2024: Claimed ₹1,00,000 ITC
• October 2024: Reversed ₹1,00,000 (Rule 37 – no payment)
• December 2024: Paid supplier, reclaimed ₹1,00,000
• March 2025: Reversed again ₹1,00,000 (Rule 37 – received credit note, adjusted payment)
• May 2025: Paid again after dispute resolved, reclaimed ₹1,00,000

GSTR-9 for FY 2024-25:

• Table 6A: ₹2,00,000 (original claim + first reclaim)
• Table 6B: ₹1,00,000 (original claim)
• Table 6H: ₹1,00,000 (first reclaim)
• Table 7A: ₹2,00,000 (both reversals: October and March)

GSTR-9 for FY 2025-26:

• Table 6H: ₹1,00,000 (second reclaim)
• Table 7A: Nothing (no reversal in this FY)

Note: The second reclaim in May 2025 is still treated as FY 2025-26 ITC, continuing the Rule 37 special treatment principle.

Interaction with Table 8 Reconciliation

Rule 37/37A’s special treatment has implications for the Table 8 reconciliation framework.

How Rule 37/37A Affects Table 8B

From FY 2024-25, Table 8B is auto-populated only from Table 6B, with Table 6H deliberately excluded. This design choice specifically accommodates Rule 37/37A scenarios.

Why this matters:

• Table 8A shows invoice once (from GSTR-2B)
• Table 8B shows original claim (from Table 6B)
• Table 6H (reclaims) doesn’t add to Table 8B
• Result: No double-counting in reconciliation

Example: Rule 37 Within Same FY

Facts:

• Claimed ₹50,000 in April 2024
• Reversed in October 2024 (Rule 37)
• Reclaimed in March 2025

Table 8 Reconciliation:

• Table 8A: ₹50,000 (invoice in GSTR-2B)
• Table 8B: ₹50,000 (from Table 6B – original claim only)
• Table 6H: ₹50,000 (reclaim, but NOT in 8B)
• Table 8C: ₹0 (not a missed claim)
• Table 8D: ₹50,000 – (₹50,000 + ₹0) = ₹0 ✓

Perfect reconciliation despite the reversal and reclaim cycle within the same FY.

Common Mistakes with Rule 37/37A Reporting

Mistake 1: Reporting Rule 37 Reclaims in Table 6A1

Wrong: Reclaimed ITC from FY 2023-24 invoice goes in Table 6A1 of FY 2024-25
Correct: Rule 37/37A reclaims NEVER go in Table 6A1; always use Table 6H

Why it matters: Incorrect 6A1 reporting distorts Table 6A2 calculation, causing Table 6J mismatch.

Mistake 2: Reporting Rule 37 Reclaims in Table 13

Wrong: ITC reversed in FY 2024-25 and reclaimed in FY 2025-26 goes in Table 13
Correct: Rule 37/37A reclaims do NOT go in Table 13 (they’re next FY’s ITC entirely)

Why it matters: Table 13 overstates ITC pertaining to FY 2024-25, creating confusion in next year’s filing.

Mistake 3: Time Limit Confusion

Wrong: Treating Rule 37 reclaims as subject to Section 16(4) time limits
Correct: Rule 37/37A reclaims have NO time limit; can be reclaimed years later

Why it matters: You might incorrectly believe old Rule 37 reversals are time-barred when they’re actually still eligible for reclaim.

Mistake 4: Reversing in Wrong Year’s GSTR-9

Wrong: Invoice from FY 2023-24 reversed in FY 2024-25, reporting reversal in FY 2023-24 GSTR-9
Correct: Report reversal in the FY when the reversal action occurred (FY 2024-25 Table 7A)

Why it matters: Reversals must match the GSTR-3B filing period, not the invoice period.

Mistake 5: Treating All Reclaims Identically

Wrong: Using Table 6H for all reclaims without distinguishing Rule 37/37A from other reasons
Correct: Non-Rule 37/37A reclaims of preceding FY invoices go in Table 6A1, not Table 6H

Why it matters: Only Rule 37/37A reclaims qualify for the special “ITC of reclaim year” treatment.

Best Practices for Rule 37/37A Management

1. Maintain a Dedicated Rule 37 Register

Track every Rule 37 reversal separately with:

• Original invoice date and FY
• Claim date and amount
• Reversal date (180th day) and amount
• Payment date (actual or planned)
• Reclaim date and amount
• Status: Pending payment / Paid / Reclaimed

This register immediately shows which FY each action belongs in for GSTR-9 reporting.

2. Set Payment Alerts at 150 Days

Don’t wait until day 180 to realize payment hasn’t been made. Set system alerts at day 150 to:

• Identify pending payments
• Process payments before reversal becomes mandatory
• Avoid the reversal-reclaim cycle altogether

3. Separately Tag Rule 37A Scenarios

When department communication indicates supplier issues (potential Rule 37A), immediately:

• Flag all ITC from that supplier
• Prepare reversal calculations
• Document the basis (department order, cancellation notice)
• Track status for potential future reclaim

4. Year-End Reversal Review

At FY-end (March), review:

• All Rule 37 reversals made during the FY → Table 7A
• All Rule 37 reclaims made during the FY → Table 6H
• Pending reclaims that will happen next FY → Not in Table 13

5. Document the Reclaim Basis

For every Rule 37/37A reclaim, maintain:

• Payment proof (bank statement, receipt)
• Date payment was made
• GSTR-3B where reclaim was reported
• Calculation showing reclaim equals original reversal

This documentation validates your Table 6H entries during audits.

6. Don’t Mix Rule 37 with Other Reversals in Your Records

Keep Rule 37/37A reversals in separate accounting codes or sub-ledgers from other ITC reversals. This prevents confusion when preparing GSTR-9 and ensures you apply the correct treatment.

The Philosophy Behind Rule 37 Treatment

Understanding why Rule 37/37A has this special treatment helps internalize the rules:

The No-Time-Limit Logic

Section 16(4) imposes time limits because taxpayers must act diligently to claim ITC on legitimate purchases. But Rule 37 is different, you already claimed the ITC legitimately; you’re merely waiting to make payment (which might be delayed for genuine commercial reasons like disputes, cash flow, etc.).

Penalizing taxpayers with time-bar restrictions when they eventually make payment would be inequitable. Hence, no time limit.

The “ITC of Reclaim Year” Logic

If Rule 37 reclaims were treated as ITC of the original invoice year, you’d face situations where:

• Invoice from FY 2020-21
• Reversed in FY 2022-23
• Reclaimed in FY 2025-26
• Should this appear in FY 2020-21 GSTR-9? (impossible – already filed years ago)

Treating reclaimed ITC as belonging to the reclaim year elegantly solves this problem. Whenever you reclaim (even years later), it simply goes in that year’s Table 6H.