GST
ITC higher than GSTR-2A or 2B in scrutiny
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Facts
Show which invoices make up the difference and whether they later appeared, were from valid suppliers, or are imports or reverse charge that do not appear in 2A. Reverse any credit you cannot support.
Provisions and law
- Sec 16, CGST Act 2017Conditions and time limit for ITC
- Instruction 02/2022-GST (22 March 2022)SOP for scrutiny: one ASMT-10 per GSTIN per year, specific and quantified discrepancies, DRC-03 payments to be considered, timelines for ASMT-12 or further action
Analysis
The SOP compares ITC with GSTR-2A, and Sec 16(2)(aa) now ties ITC to invoices reported by suppliers. Example: ₹1.1 lakh excess; ₹60,000 is import IGST, ₹30,000 is reverse charge paid in cash, and ₹20,000 is from a supplier who never filed. Explain the first two with Bills of Entry and RCM payments, and pay the ₹20,000 with interest.
Conclusion
- List the invoices behind the gap.
- Separate imports, reverse charge and ISD credit.
- Show later reflection where it happened.
- Reverse unsupported ITC through DRC-03 with interest.
- Explain the rest in ASMT-11.
A Savvy can do this for you
Scrutiny of returns, ASMT-10 notice and ASMT-11 reply
₹4,999
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