File SPL 02 Without DRC 03 A .

[Sharad Singh]

A taxpayer made payment by DRC 03 and files SPL-02 afterwards without DRC-03A. Will it be considered as payment? What will happen to such SPL-02 application. Now taxpayer can not make DRC-03 a as system doesn't allow it.

AI Summary

GST Payment Made via DRC-03 Without Filing DRC-03A: Procedural Lapse or Substantial Compliance Under Rule 142(2B)? A taxpayer made GST payment via DRC-03 but filed SPL-02 without submitting mandatory DRC-03A to link the payment. While the payment was made within the due date (31-03-2025), the system now prevents filing DRC-03A. Two perspectives emerged: some experts maintain this constitutes incomplete compliance as Form DRC-03A is legally required under Rule 142(2B) and Rule 164(2) to reconcile payments with demands in the Electronic Liability Register. Others argue the taxpayer has a valid case based on substantive compliance doctrine, as the tax amount was remitted on time and the missing DRC-03A is merely procedural, suggesting litigation may be the only remaining option.