Answer

1. F

   Facts

   No. Rule 37 does not apply to supplies on which tax is paid under reverse charge, since you pay the tax yourself.

2. P

   Provisions and law

   • Rule 37, CGST Rules 2017If the supplier is not paid within 180 days of the invoice, the proportionate ITC is shown as reversed in the GSTR-3B for the tax period immediately after the 180 days, with interest under Sec 50; it is re-availed once payment is made. Not applicable to reverse charge supplies, and to deemed supplies without consideration.
   • Sec 9(3), CGST Act 2017Tax on notified goods and services is paid by the recipient under reverse charge.
3. A

   Analysis

   For legal fees or GTA services under RCM, you pay the GST to the Government directly, so there is no tax to pass to the supplier. The 180-day reversal is not needed even if you pay the supplier late. Commercial delays are a separate matter. Make sure such purchases are tagged as RCM in your system to avoid wrong reversals.

4. C

   Conclusion

   1. 1Tag RCM purchases separately in your books.
   2. 2Exclude them from the Rule 37 ageing list.
   3. 3Ensure RCM tax was paid in cash.
   4. 4Keep RCM records for audit.

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