TaxTMI 
TaxTMI 
Dear Experts,
Shall take ITC for belated payment of RCM on ocean freight pertains 2018-19?Now paid in 10th. October 2020? Is it hit by time limit u/s 16 (4) of GST Act? Please comment.
Belated payment of RCM
11 Oct 2020 
4 Replies 
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Input tax credit for belated RCM payment may be claimed if tax paid with interest and self invoice raised on payment.
Practical compliance advice: pay the outstanding RCM tax with applicable interest, then raise a self invoice dated on the payment to claim input tax credit; this accepts the risk of late self invoicing and potential minor penalties. An alternative position is that the statutory time limit for claiming ITC has expired, so no claim is permissible. Service providers are separately obliged to issue invoices within thirty days of supply. (AI Summary)
Practical compliance advice: pay the outstanding RCM tax with applicable interest, then raise a self invoice dated on the payment to claim input tax credit; this accepts the risk of late self invoicing and potential minor penalties. An alternative position is that the statutory time limit for claiming ITC has expired, so no claim is permissible. Service providers are separately obliged to issue invoices within thirty days of supply. (AI Summary)