Answer

GST

Monthly check of GSTR-2B against GSTR-3B credit

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  1. Facts

    Compare the ITC you are about to claim in GSTR-3B Table 4 with GSTR-2B for the same month, by head. Any excess must be backed by lawful items such as import credit, RCM credit or reclaimed credit, or it can trigger DRC-01C under Rule 88D.

  2. Provisions and law

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

    Make a simple bridge: GSTR-2B ITC, minus blocked credit, minus reversals, plus RCM credit, plus reclaimed credit, equals GSTR-3B ITC. If the bridge does not close, find the item before filing. This one step prevents most DRC-01C intimations.

  4. Conclusion

    1. Download GSTR-2B after IMS actions
    2. Build the bridge to the GSTR-3B claim by head
    3. Investigate any unexplained difference
    4. File GSTR-3B only when the bridge closes

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