Answer

GST

Reverse charge purchases not in GSTR-2B

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  1. Facts

    Under reverse charge you pay the tax yourself in GSTR-3B Table 3.1(d), and claim ITC on that tax in Table 4(A)(3). Supplies from registered persons under RCM do show in 2B, but tax you pay on unregistered purchases or imported services does not.

  2. Provisions and law

    • Sec 9(3), CGST Act 2017Tax on notified goods and services is paid by the recipient under reverse charge.
    • Sec 16(2), CGST Act 2017ITC is allowed only with a tax invoice, receipt of goods or services, tax actually paid to the Government by the supplier, and the recipient's own return filed.
  3. Analysis

    RCM tax must be paid in cash, not through credit. Once paid, the same amount can be claimed as ITC if the purchase is for business and not blocked. For example, ₹50,000 of legal fees attracts ₹9,000 RCM, paid in cash and claimed back as ITC. Keep the self-invoice and payment proof.

  4. Conclusion

    1. List purchases under reverse charge for the month.
    2. Raise self-invoices where required.
    3. Pay RCM tax in cash through GSTR-3B Table 3.1(d).
    4. Claim ITC in Table 4(A)(3) where eligible.

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