Multi-state sales allocation under Rule 31D

[shalini taknet]

I am advising a trader selling tobacco products across states. Under Rule 31D, GST valuation shifts to RSP-based (e.g., MRP Rs. 1000, 28% slab ? taxable value ~Rs. 218 after extraction). But for actual sales- Rs. 300 IGST to Maharashtra Rs. 400 CGST+SGST in Haryana, how do we allocate and report this output tax in GSTR-1/3B? Full RSP or apportioned by invoice value? Practical workarounds for e-invoicing mismatches?

[NYAYASETU LEGAL ASSOCIATES LLP]

You have to do reverse calculation of taxable value on the basis of RSP divided by 1.28 and same taxable value you to report in GSTR-1 & 3B (You should not report actual sale value therein).  Further as far as E-invoicing scheme is concerned you also need to mention above taxable value and tax so that both will be equal to invoice value and to match with your taxable value you need to insert discount therein.

[Raam Srinivasan Swaminathan Kalpathi]

Dear Querist

RSP is cum tax value. Please work backwards and arrive at the taxable value. This specific issue is addressed in Rule 35 of the CGST Rules, 2017. 

Thanks

[Hitesh Jain]

Under Rule 31D, the RSP/MRP is treated as a cum-tax value and not the taxable value itself. So for GST reporting in GSTR-1 and GSTR-3B, you should reverse-calculate the taxable value from the RSP (e.g., divide by 1.28 for 28% slab) and then report that computed value along with the corresponding tax. This approach aligns with how valuation under Rule 31D works and is consistent with what experienced practitioners have pointed out here.

Since your actual invoice values (IGST vs CGST + SGST splits) will differ from the reverse-calculated taxable value, you can show a discount or adjustment in the e-invoice so that the total consideration on the invoice matches the price received, while your returns reflect the correct taxable value. That helps avoid mismatches between e-invoicing and return filings.

If you need precise numbers for your specific case, it's best to apply the reverse calculation on each sale and ensure consistency between invoice and return reporting.

AI Summary

RSP treated as cum tax value: reverse calculate taxable value and report it in returns, reconcile via invoice discounts. RSP is a cum tax value and must be reverse calculated to obtain the taxable value; that computed taxable value and the corresponding tax must be reported in GSTR 1 and GSTR 3B rather than the gross invoice sale amount. To avoid mismatches with e invoicing, record an appropriate discount or adjustment on the invoice so the amount received aligns with the reverse calculated taxable value reported in returns.