Answer

1. F

   Facts

   Year-wise differences between ITC claimed in GSTR-3B and GSTR-2B are a frequent DRC-01A topic. Valid reasons include RCM, imports, timing differences and credit appearing in later 2Bs.

2. P

   Provisions and law

   • Rule 36(4), CGST Rules 2017ITC can be taken only on invoices and debit notes furnished by suppliers in GSTR-1 or IFF and communicated in GSTR-2B.
   • Sec 16(2)(aa), CGST Act 2017ITC is allowed only if the supplier has reported the invoice in GSTR-1 or IFF and it is communicated to the recipient.
   • Rule 142(1A), CGST Rules 2017Before a show cause notice, the officer may communicate the tax, interest and penalty ascertained in Part A of DRC-01A; the person may pay or give submissions in Part B.
3. A

   Analysis

   Prepare a reconciliation starting from the 2B total, adding RCM credit, import credit and prior-year credit claimed, and deducting reversals. Each bridge item needs proof, such as RCM payment or Bills of Entry. For periods before 2B was binding, Circular 183/15/2022-GST allowed verification with supplier certificates for FY 2017-18 and 2018-19. Pay only the true unexplained excess.

4. C

   Conclusion

   1. 1Download 2B for all months of the year.
   2. 2Build a bridge from 2B ITC to 3B ITC.
   3. 3Attach proof for each bridge item.
   4. 4Pay any unexplained excess with interest through DRC-03.
   5. 5File Part B with the reconciliation.

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