GST
Paying GSTR-3B while ITC is blocked
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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.
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
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.
Conclusion
- Work out output tax for the month.
- Use unblocked credit first.
- Create a PMT-06 challan for the balance and pay.
- File GSTR-3B by the due date.
- Make a cash plan for the next few months.
A Savvy can do this for you
Credit ledger blocked under Rule 86A: representation and unblocking
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