GST
RCM liability check in GSTR-9C
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Facts
Expenses in the books on which reverse charge applies, such as legal fees from advocates, GTA freight and certain imports of services, should match RCM tax paid in returns.
Provisions and law
- Sec 9(3), CGST Act 2017Tax on notified goods and services is paid by the recipient under reverse charge.
- Rule 80(3), CGST Rules 2017A taxpayer whose aggregate turnover exceeds ₹5 crore files a self-certified reconciliation statement in GSTR-9C along with GSTR-9.
Analysis
Scan the ledger for advocates' fees, freight, sponsorship, director fees and imported services. Compare with RCM paid in GSTR-3B. If RCM was missed, pay it with interest through DRC-03; ITC may then be available, subject to Sec 16(4) timing. This is one of the most common gaps found in 9C.
Conclusion
- Pull ledgers for RCM-type expenses.
- Compute RCM due on them.
- Compare with RCM paid in returns.
- Pay any shortfall with interest through DRC-03.
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GSTR-9C reconciliation statement
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