Answer

GST

Allocating lump sum payments to supplier invoices

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  1. Facts

    Rule 37 looks at whether the invoice value has been paid within 180 days. With on-account payments, a clear allocation to invoices is needed to show which are paid.

  2. Provisions and law

    • Rule 37, CGST Rules 2017If the supplier is not paid within 180 days of the invoice, the proportionate ITC is shown as reversed in the GSTR-3B for the tax period immediately after the 180 days, with interest under Sec 50; it is re-availed once payment is made. Not applicable to reverse charge supplies, and to deemed supplies without consideration.
    • Sec 155, CGST Act 2017The person who claims ITC has the burden of proving that the claim is genuine.
  3. Analysis

    A common method is first in first out: payments settle the oldest invoices first. Agree the method with the supplier and keep ledger confirmations. If your books show a running balance, prepare an ageing report showing invoices above 180 days. Without allocation, an auditor may treat all old invoices as unpaid.

  4. Conclusion

    1. Agree a payment allocation method with suppliers.
    2. Apply it consistently in your books.
    3. Run an invoice ageing report each month.
    4. Get yearly balance confirmations.

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ITC reversal for unpaid suppliers after 180 days, Rule 37

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