Answer

GST

DRC-01A for unpaid reverse charge

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  1. Facts

    Services such as legal services by an advocate and goods transport by a GTA (where notified) attract reverse charge under Sec 9(3). The buyer pays the tax. Missed RCM is a common demand ground.

  2. Provisions and law

    • Sec 9(3), CGST Act 2017Tax on notified supplies paid by the recipient under reverse charge
    • Rule 142(2A), CGST Rules 2017After DRC-01A, the person may pay in full or part through DRC-03 or file submissions in Part B
  3. Analysis

    If the RCM was missed, pay the tax with interest through DRC-03. The tax paid can usually be claimed as ITC, so the real cost is the interest. If a GTA charged forward GST, explain that RCM did not apply.

  4. Conclusion

    1. List advocate and transport expenses for the period.
    2. Check which attract RCM.
    3. Pay missed RCM with interest through DRC-03.
    4. Claim ITC where allowed and reply in Part B.

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