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RCM - liability to be discharged as per books or as per gstr2b, Goods and Services Tax - GST

Issue Id: - 117765
Dated: 17-1-2022
By:- Govinda Raju
RCM - liability to be discharged as per books or as per gstr2b

  • Contents

Invoices (service/goods/GTA) from un-registered person to registered person –

1. We have to create liability under RCM and discharge our liability or pay just as per GSTR-2B.

2. RCM Invoices will be declared in GSTR-2B under RCM but not accounted by us in same month due to transit or delayed receipt of invoices from GTA provider/goods. –

Still we have to discharge liability as per GSTR-2B or as per books or

keep reco in our books and discharge liability as per GSTR-2B.

3. what about unregistered supplier/GTA invoices where it will not appear in GSTR-2B but will be accounted in books – we need discharge liability by adding value/tax in GSTR-2B – or pay just as per GSTR-2B.

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Posts / Replies

Showing Replies 1 to 7 of 7 Records

1 Dated: 17-1-2022

See reply against Issue ID 117763.

2 Dated: 18-1-2022
By:- Shilpi Jain

Discharge of liability under RCM is on the basis of the time of supply provision contained in sec 13(3) and 12(3) of the CGST Act. It is not based on the appearance in GSTR-2B.

3 Dated: 19-1-2022

I agree with Madam Shilpi Jain.

4 Dated: 19-1-2022
By:- Govinda Raju

Thanks Madam Shilpi Jain for your kind response and also to Mr. Kasturi Sethi.



5 Dated: 21-1-2022
By:- Ganeshan Kalyani

In this month system generated GSTR-3B the RCM ITC auto-populated based on GSTR-1/IFF of the supplier. Some transaction had taxable value alone and no GST. The table in 3B shown the red mark indicating more ITC taken than in GSTR-3B. This also need a reconciliation to be prepared and kept to answer to department query on the difference in ITC claimed in GSTR-3B self prepared and GSTR-3B system generated.

6 Dated: 22-1-2022
By:- CAHemanth Kumar

Time of supply as per section 13(3)

1. Earlier of date of payment as entered in books or amount debited in bank account or

2. 61st day from the date of invoice or any other document issued by the suppier.

if it is not possible to determine the time of supply as above, ToS shall be the date of entry in the books of account of the recipient of supply:

Irrespective of what it appears in GSTR-2B, RCM needs to be paid as per books and once we edit RCM liabilities in auto populated GSTR-3B, it may give u a warning red indication, we need to keep details/reasons for the same. We may not know when dept will issue a sudden notice for system computed difference .

7 Dated: 22-1-2022
By:- Govinda Raju

Thank you Mr. Ganeshan Kalyani and Mr. Hemanth Kumar.


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