Answer

GST

Paying GSTR-3B while ITC is blocked

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  1. Facts

    You still file GSTR-3B on time. Tax that the blocked credit would have covered must be paid in cash, or from any credit that is not blocked.

  2. Provisions and law

    • Rule 86A(1), CGST Rules 2017Commissioner or authorised officer, not below Assistant Commissioner, may disallow debit of ITC for recorded reasons where the supplier or recipient is non-existent, goods were not received, tax was not paid or there is no valid document
    • Sec 50(1), CGST Act 2017Interest at 18 percent a year on tax paid late
  3. Analysis

    Rule 86A only stops debit of the blocked amount; it does not suspend your return. Late filing brings late fee, and late tax brings interest under Sec 50(1). Example: output tax ₹4 lakh, unblocked credit ₹1.5 lakh, so pay ₹2.5 lakh by challan before filing. Plan cash for the coming months too, as the block may last up to a year.

  4. Conclusion

    1. Work out output tax for the month.
    2. Use unblocked credit first.
    3. Create a PMT-06 challan for the balance and pay.
    4. File GSTR-3B by the due date.
    5. Make a cash plan for the next few months.

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Credit ledger blocked under Rule 86A: representation and unblocking

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