GST
Partly agreeing with a DRC-01A
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Facts
Yes. Part B of DRC-01A allows you to pay part of the amount and file submissions against the rest. The officer may accept the payment, the submissions, or both.
Provisions and law
- Rule 142(1A), CGST Rules 2017Before a show cause notice, the officer may communicate the tax, interest and penalty ascertained in Part A of DRC-01A; the person may pay or give submissions in Part B.
- Rule 142(2), CGST Rules 2017A person paying tax, interest and penalty voluntarily or after an intimation informs the officer in DRC-03, and an acknowledgement issues in DRC-04.
Analysis
Pay what you agree through DRC-03 and explain the disputed part with reconciliation and documents. For example, of ₹2 lakh shown, you may accept ₹40,000 for a missed RCM entry and dispute ₹1.6 lakh that relates to credit notes. The show cause notice, if issued, should then cover only the disputed part. Keep the explanation simple and month-wise.
Conclusion
- Split the amount into agreed and disputed parts.
- Pay the agreed part with interest through DRC-03.
- Prepare a reconciliation for the disputed part.
- File Part B with payment details and submissions.
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Pre-show-cause intimation
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