50 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A bank makes exempt supplies (interest on loans and advances) and taxable supplies (fees, commission, locker rent, forex) from the same infrastructure. Running Rule 42 across thousands of branches and hundreds of cost centres is an enormous exercise for a ratio that barely moves.
Section 17(4) offers a way out: take half, and stop computing.
A banking company, a financial institution including a non-banking financial company, engaged in supplying services by way of accepting deposits, extending loans or advances, has the option to either comply with s.17(2), or to avail every month an amount equal to fifty per cent of the eligible input tax credit on inputs, capital goods and input services in that month. The option once exercised shall not be withdrawn during the remaining part of the financial year. Rule 38 carries the procedure — and the proviso to s.17(4) excludes supplies between distinct persons from the 50% restriction.
Who can elect
Three descriptions, all of which must also be engaged in supplying services by way of accepting deposits, extending loans or advances:
- a banking company;
- a financial institution; and
- a non-banking financial company.
An entity that is an NBFC but does not lend or accept deposits — a pure investment company, for instance — does not fit the description.
What the 50% applies to
Fifty per cent of the eligible input tax credit on inputs, capital goods and input services in that month. The remaining fifty per cent lapses.
Two words carry weight.
"Eligible." The 50% is applied after removing credit blocked under s.17(5). A bank does not take 50% of blocked credit; it takes 50% of what was otherwise available.
"Every month." The election operates monthly within the year, applied to that month's credit. It is not an annual computation.
The distinct-person carve-out
The proviso to s.17(4):
"Provided that the restriction of fifty per cent. shall not apply to the tax paid on supplies made by one registered person to another registered person having the same Permanent Account Number."
This is significant for any bank or NBFC with multiple State registrations.
A head office cross-charging services to State branches — all under the same PAN — supplies credit that the receiving branch takes in full, not at 50%. Without the proviso, a group centralising IT, treasury or shared services in one State would lose half the credit at every internal transfer, on top of the 50% it loses on external procurement.
The carve-out is drafted by reference to the same PAN, not to "distinct persons" — so it covers any two registrations of the same legal entity, including multiple registrations within one State.
The election: annual and irrevocable
"...the option once exercised shall not be withdrawn during the remaining part of the financial year."
Rule 38 requires the banking company or financial institution to:
- not avail the credit of tax paid on inputs and input services used for non-business purposes and the credit attributable to blocked supplies under s.17(5) in FORM GSTR-2;
- avail the credit of tax paid on inputs and input services referred to in the proviso to s.17(4) — the same-PAN supplies — and on inputs and input services used for non-business purposes to the extent stated;
- the remaining amount of credit is to be restricted to fifty per cent and the balance lapses;
- the amount so availed is furnished in FORM GSTR-3B.
The rule refers to GSTR-2, which is not operational; in practice the mechanics are worked through GSTR-3B and GSTR-2B.
Choosing between the two
The 50% option is better where more than half the credit would otherwise be reversed under Rule 42 — that is, where exempt turnover exceeds roughly 50% of total turnover. For a typical lending institution, interest income dwarfs fee income, so the exempt ratio is well above 50% and the option is clearly favourable.
The 50% option is worse where the taxable proportion is high — a bank whose income is predominantly fee-based, or an NBFC with a large advisory arm.
Two other factors:
Compliance cost. Rule 42 across a branch network is expensive to run and to defend. The 50% option removes an entire audit exposure.
Volatility. Rule 42's ratio moves with turnover mix and requires an annual true-up with interest. The 50% option is stable.
Because the election is irrevocable within the year, it should be modelled on the previous year's actuals before April.
Practical notes
- Exercise and document the election before the first return of the financial year.
- Strip out s.17(5) credit first. The 50% applies to eligible credit only.
- Identify same-PAN inward supplies separately — they escape the 50% entirely.
- The lapsed 50% is a cost. It is not carried forward and cannot be refunded.
- Zero-rated supplies: a bank making exports of services should model whether the 50% option interacts unfavourably with an export refund claim, since the lapsed credit is not refundable.
- Reconcile to GSTR-9 Table 7 and Table 8, where the lapse has to be visible.
Key takeaways
- s.17(4) lets a bank, financial institution or NBFC take 50% of eligible credit monthly instead of Rule 42.
- The remaining 50% lapses.
- The option is annual and irrevocable within the financial year.
- The proviso excludes same-PAN supplies — inter-branch credit is available in full.
- The 50% applies after removing s.17(5) blocked credit.
- Rule 38 carries the procedure.
Read next
- Section 17(1) and 17(2): Two Apportionments
- Rule 42 Worked: The Monthly Formula and Annual True-Up
- Section 17(3): What Counts as Exempt Supply
- GST on Banking Services
Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition).