Answer

GST

Reversing doubtful ITC to get the block lifted

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  1. Facts

    Sometimes reversing credit on a genuinely doubtful invoice and asking for release of the rest is practical. Reverse only after checking each invoice, because a reversal is treated as accepting the credit was ineligible.

  2. Provisions and law

    • Rule 86A(2), CGST Rules 2017The officer may allow the debit, fully or partly, once satisfied that the conditions no longer exist
    • Sec 73, CGST Act 2017Demand of tax and ITC wrongly availed, non-fraud cases
    • Rule 142(2), CGST Rules 2017Voluntary payment intimated in DRC-03
  3. Analysis

    Rule 86A(2) lets the officer release credit once the concern is addressed. If one supplier truly cannot be traced and you cannot prove receipt, paying that ITC with interest through DRC-03 can close that part and support release of the rest. But do not reverse invoices you can defend. Example: ₹1.2 lakh from a supplier with no transport proof could be paid; ₹6 lakh from verified suppliers should be defended.

  4. Conclusion

    1. Sort blocked invoices into defensible and doubtful.
    2. Take advice on the doubtful ones.
    3. Pay any accepted amount with interest through DRC-03 and keep the ARN.
    4. Send the DRC-03 copy with a request to release the rest.
    5. Defend the remaining invoices with evidence.

A reversal can be used against you later, so do it only after review.

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