TaxTMI 
TaxTMI 
Sir. GTA Expenses accounted in books during the year 2020-21, and RCM was not paid with in the year. Can i pay RCM in November 2021 and Claim ITC?
Reverse Charge Mechanism
18 Nov 2021 
23 Replies 
9875 Views Asked by
Input tax credit timing: belated reverse charge payment may be time barred unless debit note issuance meets prescribed criteria.
Querist delayed issuing self-invoice and paying reverse-charge tax for transport services and proposes to pay RCM later and claim ITC. Opinions diverge: one view treats failure to issue timely self-invoice as time-barred for ITC despite belated payment and warns of interest, penalties and need for departmental approval; an alternative view treats belated documents as debit notes/supplementary invoices and, relying on administrative clarification that debit note date governs ITC timing, contends ITC may be claimable within the debit-note time window. The issue is fact-specific and contested. (AI Summary)
Querist delayed issuing self-invoice and paying reverse-charge tax for transport services and proposes to pay RCM later and claim ITC. Opinions diverge: one view treats failure to issue timely self-invoice as time-barred for ITC despite belated payment and warns of interest, penalties and need for departmental approval; an alternative view treats belated documents as debit notes/supplementary invoices and, relying on administrative clarification that debit note date governs ITC timing, contends ITC may be claimable within the debit-note time window. The issue is fact-specific and contested. (AI Summary)