Answer

GST

Reverse charge ITC shown as excess over GSTR-2B

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  1. Facts

    ITC on reverse charge is claimed on tax you paid yourself, so it does not come from a supplier's GSTR-1 in the same way. Depending on how it was reported in GSTR-3B, it can show as a difference against GSTR-2B. GSTN also offers an RCM ITC statement to track this credit.

  2. Provisions and law

    • Sec 9(3), CGST Act 2017Tax on notified supplies is paid by the recipient under reverse charge
    • Sec 16(2), CGST Act 2017ITC needs a tax invoice, receipt of goods or services, tax paid by the supplier and a filed return
    • Rule 88D, CGST Rules 2017Intimation DRC-01C when ITC in GSTR-3B exceeds GSTR-2B beyond a limit; reply in 7 days
  3. Analysis

    If you claimed RCM credit of ₹36,000 in Table 4(A)(3) after paying ₹36,000 RCM tax in cash in Table 3.1(d), explain this in Part B with the challan or GSTR-3B reference. Check that the RCM credit was not also typed into the 'all other ITC' row, which would double it. Keep the RCM liability and credit equal each month where fully eligible.

  4. Conclusion

    1. Check the RCM liability paid in Table 3.1(d)
    2. Check RCM credit is only in Table 4(A)(3)
    3. Explain the RCM amount in Part B
    4. Use the RCM ITC statement to keep a running balance

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