GST
My own GSTIN suspended because of a supplier
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Facts
Your registration can be suspended under Rule 21A if the officer finds serious discrepancies in your own returns, such as large ITC differences. A supplier's fraud can trigger this if it shows up as a mismatch in your credit.
Provisions and law
- Rule 21A, CGST Rules 2017Registration can be suspended while cancellation proceedings are pending, including for significant return mismatches
- Rule 21, CGST Rules 2017Registration can be cancelled if the person issues invoices without supply or does not conduct business from the declared place
- Sec 155, CGST Act 2017The burden of proving eligibility for ITC lies on the person claiming it
Analysis
While suspended you cannot issue tax invoices or claim refunds, and business stops. Example: your GSTR-3B credit is Rs 15 lakh higher than 2B because of a supplier who stopped filing; the system flags you. Reply with the reconciliation, reverse credit not supported by 2B, and show proof. Most suspensions are revoked on a proper reply.
Conclusion
- Read the REG-31 or REG-17 notice and the discrepancy shown
- Reconcile your ITC with GSTR-2B for the periods
- Reverse unsupported credit with interest where required
- File the reply with documents within the deadline
- Track revocation and keep proof
A Savvy can do this for you
Supplier due diligence: GSTIN, filing history, 2B and IMS match, red flags
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