GST
Officer can still question a DRC-01C reply
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Facts
Filing Part B lifts the GSTR-1 block. It does not stop the officer from examining the issue later through scrutiny under Sec 61, a DRC-01A intimation or a show cause notice, if the explanation is not accepted.
Provisions and law
- Sec 61, CGST Act 2017Scrutiny of returns by the proper officer
- Rule 142(1A), CGST Rules 2017Pre-notice intimation in DRC-01A, before a show cause notice
- Rule 88D, CGST Rules 2017Intimation DRC-01C when ITC in GSTR-3B exceeds GSTR-2B beyond a limit; reply in 7 days
Analysis
Most accepted explanations are never raised again. But explanations without support, such as 'supplier will file', are often revisited. If the supplier still has not filed by the time of scrutiny, expect a demand for that credit. Fix the root cause rather than relying on the reply alone.
Conclusion
- Track whether the explained items resolve, such as supplier filing
- Pay back items that do not resolve
- Keep the reconciliation updated
- Respond quickly to any ASMT-10 or DRC-01A
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