Answer

GST

Keeping a reconciliation file for DRC-01C replies

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  1. Facts

    Your Part B text is short, so the support sits in your file. Keep a reconciliation of GSTR-2B to GSTR-3B for the period, invoice lists for each cause, bills of entry, RCM challans and ledger extracts. Books must be kept for 72 months under Sec 36.

  2. Provisions and law

    • Sec 35, CGST Act 2017Accounts and records to be kept at the principal place of business
    • Sec 36, CGST Act 2017Books and records must be kept for 72 months from the annual return due date
    • Rule 88D, CGST Rules 2017Intimation DRC-01C when ITC in GSTR-3B exceeds GSTR-2B beyond a limit; reply in 7 days
  3. Analysis

    Officers who later issue ASMT-10 or DRC-01A often ask for the same reconciliation. If it is ready, the reply takes a day. A good file shows the GSTR-2B figure, each adjustment with amount and evidence, and the GSTR-3B figure.

  4. Conclusion

    1. Prepare a GSTR-2B to GSTR-3B bridge for the period
    2. Attach invoice lists and documents for each item
    3. Save the filed DRC-01C and any DRC-03
    4. Store everything with the month's return papers

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