RCM ITC availability of FY 17-18

[Ashiesh Prremji]

Whether we can avail ITC on RCM for FY 17-18 in 3B of Nov 19 before filing GSTR 9 ??

[Rajendra Prasad]

Dear Mr Ashiesh,

As per the point no. g of press note dated 3rd July 2019 , RCM of FY 2017-18 , paid in FY 2018-19 is to be shown in FY 2018-19. But your situation is slightly differs i.e. FY 2017-18 RCM in FY 2019-20. Liberally we can interpret that we can claim in the year of payment.

In my opinion is it to be shown under normal place only. i.e. Point No. 4(A)(3) of GSTR 3B.

[Ashiesh Prremji]

Thanks for reply! So, unpaid liability on RCM of FY 17-18 which we will pay in 19-20 with interest can claim in 19-20 & accordingly to be shown in GSTR-9 of 19-20.

If yes, then this point will come in GST Audit Report also that such liability has been paid in FY 19-20, because this will not be shown in GSTR-9 of 17-18.

[Rajendra Prasad]

Dear Ashiesh,

No need to show in GSTR 9 / 9C of 2017-18 FY. But being the Auditor for FY 2017-18 , please mention the RCM payment particulars and a small note in comments section of GSTR-9C of 2017-18 FY.

AI Summary

Reverse charge Input Tax Credit: claim in the year of payment and report in the regular periodic return.
Reverse charge Input Tax Credit for supplies of a prior financial year is claimable in the year when the reverse charge liability is paid and should be reported in the standard periodic return line for payment-led credits; auditors of the earlier year should record payment particulars and insert a comment in the annual return audit reconciliation to note that the liability was discharged and claimed in a subsequent year.