RCM - liability to be discharged as per books or as per gstr2b

[Govinda Raju]

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.

[KASTURI SETHI]

See reply against Issue ID 117763.

[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.

[KASTURI SETHI]

I agree with Madam Shilpi Jain.

[Govinda Raju]

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

Regards

GR

[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.

[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 .

[Govinda Raju]

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

AI Summary

Debate on GST liability discharge under RCM: GSTR-2B vs. accounting books; clarify using CGST Act time of supply provisions. A discussion on the Goods and Services Tax (GST) forum addresses the issue of discharging liability under the Reverse Charge Mechanism (RCM) based on GSTR-2B or accounting books. Participants debate whether liabilities should be discharged according to GSTR-2B entries or as per the books, especially when invoices from unregistered suppliers or delayed invoices are involved. It is clarified that liability under RCM should be discharged based on the time of supply provisions in the CGST Act, not solely on GSTR-2B entries. Participants also discuss reconciling discrepancies between GSTR-3B and system-generated data to address potential departmental queries.