Answer

GST

IMS actions that change GSTR-2B and cause a DRC-01C

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  1. Facts

    Your GSTR-2B is built from IMS. Rejected records are removed from GSTR-2B and pending ones are held back. If you claim credit on such invoices in GSTR-3B, the claim exceeds GSTR-2B and DRC-01C can follow.

  2. Provisions and law

    • Sec 16(2)(aa), CGST Act 2017ITC only when the invoice is furnished by the supplier and communicated in GSTR-2B
    • Rule 36(4), CGST Rules 2017ITC on invoices is allowed only if they are reported by the supplier and appear in GSTR-2B
    • Rule 88D, CGST Rules 2017Intimation DRC-01C when ITC in GSTR-3B exceeds GSTR-2B beyond a limit; reply in 7 days
  3. Analysis

    If you rejected an invoice of ₹70,000 tax in IMS because of a quantity dispute, do not claim it in GSTR-3B. If you later accept it, recompute GSTR-2B before filing. A DRC-01C caused by your own IMS action is best closed by paying back through DRC-03.

  4. Conclusion

    1. Compare IMS actions with what you claimed in GSTR-3B
    2. Pay back or explain the difference in Part B
    3. Recompute GSTR-2B whenever you change an IMS action
    4. Claim only from the final GSTR-2B

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