RCM OF FY2021 ,PAID IN NEXT YEAR

[PAWAN BANSAL]

Dear Professional

We have received services in the month of march ,21 on which RCM applies,but forget to shown in 3B of march,21 as liability.

Can we show it in the month of April,21 and take the credit later in the month of payment ?

in which month ,are we supposed to issue Self Invoice??

will the reply will be same if we not booked the liability of RCM of march21 in the month of march,21 itself.??(we booked in the month of April,21)

Thanks & Regards

[MUKUND THAKKAR]

In case of reverse charge, the time of supply shall be the earliest of the following dates:

The date of payment

The date immediately after 60 days from the date of issue of invoice by the supplier

If it is not possible to determine the time of supply, the time of supply shall be the date of entry in the books of account of the recipient.

Date of payment 15th July 2020

Date immediately after 60 days from the date of issue of invoice (Suppose the date of invoice is 15th May 2020, then 60 days from this date will be 14th July 2020)

Date of entry in books of receiver 18th July 2020

The Time of supply of service, in this case, will be 14th July 2020

[PAWAN KUMAR]

Dear Sir,

as per my view, The time of supply in case of reverse charges of services :

the date which entry made in the books of account of receiver or date of debit in bank account of receiver , whichever is earlier

or

the date after sixty days from the date of invoice of service provider.

in case if both not applicable, then the time of supply will be date of entry in books of account of receiver.

in your case services received during March 21, hence entry in your books during March 21, you need to pay tax assuming liability of March 21 along with interest and during the tax period in which you will pay the GST, it will claim in that same month.

[Ganeshan Kalyani]

Yes you can show as liability and take ITC in Apr-21 GSTR 3B.

Self invoice can be raised in May 21 before filing date of 3B return as only based on self-invoice ITC is allowed.

[KASTURI SETHI]

Another aspect which has to be taken care of is that service receiver under RCM is deemed service provider (supplier).

[Ganeshan Kalyani]

My apology, instead of Apr21 I mentioned as May21. Pls. read as 'Apr21'.

[Shilpi Jain]

Pls note that self-invoice will be required only if your supplier is unregistered. There is no time limit mentioned for its issue. So you can issue it in the month in which you are mentioning its details in the return.

The time of booking that liability in the books has no relevance to when it should be disclosed in the return.

The Time of supply mentioned by the experts is relevant.

AI Summary

Reverse charge timing: time of supply governs when tax is due and when input tax credit may be claimed. Reverse charge liability is fixed by the time of supply rules: the earliest of payment date, the date after sixty days from supplier's invoice, or the date of entry in recipient's books. The time of supply, not the mere booking date, determines the period for reporting and discharging tax. If the supplier is unregistered, a self-invoice may be issued when reporting the liability in the return; input tax credit under reverse charge is claimable in the period in which tax is paid, consistent with these timing rules.