Answer

GST

GSTR-1 versus GSTR-3B mismatch in scrutiny

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  1. Facts

    The most common scrutiny point is a difference between tax declared in GSTR-1 and tax paid in GSTR-3B. Many differences have valid reasons, such as amendments, advances or invoices reported in a different month.

  2. Provisions and law

    • Sec 61, CGST Act 2017Proper officer may scrutinise returns, inform discrepancies and seek an explanation
    • Rule 99, CGST Rules 2017Discrepancies are sent in ASMT-10; reply in ASMT-11 within 30 days or extended time; ASMT-12 closes the matter
    • Sec 50, CGST Act 2017Interest at 18 percent on tax paid late, and on ITC wrongly availed and utilised
  3. Analysis

    Prepare a month-wise table: GSTR-1 tax, GSTR-1 amendments, GSTR-3B tax, and the reason for each gap. Example: GSTR-1 shows Rs 18 lakh CGST, 3B shows Rs 17.4 lakh; Rs 40,000 is invoices reported in GSTR-1 of March but paid in April 3B, and Rs 20,000 is truly short. Show the timing difference with dates and pay Rs 20,000 with interest through DRC-03.

  4. Conclusion

    1. Build a month-wise GSTR-1 versus GSTR-3B reconciliation
    2. Tag each gap as timing, amendment, error or short payment
    3. Pay genuine short payment with interest through DRC-03
    4. Attach the reconciliation and DRC-03 ARN with ASMT-11

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Scrutiny of returns

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