Part III  of GST Audit Series: 6 Case Studies on Reverse Charge Mechanism (RCM) reporting in GSTR-9 & 9C of FY 2018-19.

Issues discussed regarding-

1. How to report 17-18 transactions of RCM paid in 18-19?

2. RCM paid by DRC 03, how to report?

3. How to report RCM issues in GSTR 9 and 9C?

4. Summary table of RCM reporting.

Also Read-

12 Case Studies on Outward Supplies of FY 17-18 reporting in GSTR-9 & 9C of FY 2018-19

12 Case Studies on Inward Supplies of FY 17-18 reporting in GSTR 9 & 9C of FY 18-19

Draft Disclosures for GST Audit Report of F.Y. 2018-19

 For guidance purpose only. Check your facts and figures.
 Case 1: Short RCM Paid in 3B of FY: 2017-18, Paid in 3B of FY: 2018-19.
 Year  Table No.  Particulars  Amount
 2017-18    As per Books 500
     As per 3B 400
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 400
Table 6C and 6D Inward supplies received from unregistered persons (6C) or Registered person (6D) (as the case may be) liable to reverse charge (other than B above) on which tax is paid & ITC availed 400
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 400
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 400
 2018-19    As per Books 200
     As per 3B 300
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 300
Table 6C and 6D Inward supplies received from unregistered persons (6C) or Registered person (6D) (as the case may be) liable to reverse charge (other than B above) on which tax is paid & ITC availed 300
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 300
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 300
Table 12A ITC availed as per audited Annual Financial Statement 200
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year 100
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years 0
Table 12D ITC availed as per audited fnancial statements or books of account 300
Table 12E ITC claimed in Annual Return (GSTR9) 300
Precaution: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.
 Case 2: Short RCM Paid in 3B of FY: 2018-19, Paid in 3B of FY: 2019-20.
 Year Table No.  Particulars  Amount
 2018-19    As per Books 300
     As per 3B 200
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 200
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 200
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 200
Table 9Q Total amount paid as declared in Annual Return (GSTR 9)  200
Table 12A ITC availed as per audited Annual Financial Statement 300
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years  100
Table 12D ITC availed as per audited fnancial statements or books of account  200
Table 12E ITC claimed in Annual Return (GSTR9) 200
 2019-20    As per Books 400
     As per 3B  500
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 500
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 500
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 500
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 500
Table 12A ITC availed as per audited Annual Financial Statement  400
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year  100
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years
Table 12D ITC availed as per audited fnancial statements or books of account 500
Table 12E ITC claimed in Annual Return (GSTR9) 500
Note: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.
 Case 3: Short RCM Paid in 3B of FY: 2018-19 , Paid during the audit through DRC-03 in FY: 2020-21(Now).
 Year  Table No.  Particulars  Amount
 2018-19    As per Books 300
     As per 3B 200
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 200
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 200
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 200
Table 9Q Total amount paid as declared in Annual
Return (GSTR 9)
200
Table 12A ITC availed as per audited Annual Financial Statement 300
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year  –
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years  –
Table 12D ITC availed as per audited fnancial statements or books of account 300
Table 12E ITC claimed in Annual Return (GSTR9) 200
Table 12F Unreconciled Balance 100
Note: RCM paid through DRC-03 and claimed in FY: 20-21 related to the FY:18-19 100
 2019-20    As per Books 300
     As per 3B 300
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 300
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 300
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 300
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 300
Table 12A ITC availed as per audited Annual Financial Statement 300
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years  –
Table 12D ITC availed as per audited fnancial statements or books of account 300
Table 12E ITC claimed in Annual Return (GSTR9) 300
2020-21    As per Books 400
     As per 3B 500
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 500
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 500
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 500
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 500
Table 12A ITC availed as per audited Annual Financial Statement 400
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years
Table 12D ITC availed as per audited fnancial statements or books of account 400
Table 12E ITC claimed in Annual Return (GSTR9) 500
Table 12F Unrecocilled Balance -100
Note: RCM paid through DRC-03 and claimed in FY: 20-21 related to the FY:18-19 -100
Note: If Short of FY: 2018-19 paid through DRC-03 in FY: 2020-21 then in GSTR-3B of FY: 2020-21 required to report in only ITC coloum.
Note: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.
 Case 4: Excess RCM Paid in 3B of FY:2017-18 – Claim as per 3B in GSTR-9 of the FY:2017-18
 Year Table No.  Particulars  Amount
 2017-18    As per Books 400
     As per 3B 500
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 500
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 500
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 500
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 500
Table 12A ITC availed as per audited Annual Financial Statement 500
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year 0
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years 0
Table 12D ITC availed as per audited fnancial statements or books of account 500
Table 12E ITC claimed in Annual Return (GSTR9)  500
Table 12F Unreconcilled Balance
Note: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.
 Case 5: Excess RCM Paid in 3B of FY: 2018-19 – Claim as per 3B in GSTR-9 of FY:2018-19
 Year  Table No.  Particulars  Amount
 2018-19    As per Books (Actul RCM as per Book 300/- and 100/- of Excess RCM paid considered as ITC accounted in book for Table 12A). 300
     As per 3B 400
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis  400
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 400
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 400
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 400
Table 12A ITC availed as per audited Annual Financial Statement 400
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year 0
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years 0
Table 12D ITC availed as per audited fnancial statements or books of account 400
Table 12E ITC claimed in Annual Return (GSTR9) 400
Note: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.
Case 6: Excess RCM Paid in 3B of FY:2017-18 and FY: 2018-19 – Claim as per 3B in GSTR-9 of FY:2017-18 and 2018-19.
 Year Table No.  Particulars  Amount
 2017-18    As per Books 400
     As per 3B  500
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 500
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed  500
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 500
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 500
 2018-19    As per Books (Actul RCM as per Book 300/- and 100/- of Excess RCM paid considered as ITC accounted in book for Table 12A). 300
     As per 3B 400
 GSTR 9
Table 4G Inward supplies on which tax is to be paid on reverse charge basis 400
Table 6C and 6D Inward supplies received from unregistered persons or Registered person liable to reverse charge (other than B above) on which tax is paid & ITC availed 400
 GSTR 9C
Table 9 Reconciliation of rate wise liability and amount payable thereon 400
Table 9Q Total amount paid as declared in Annual Return (GSTR 9) 400
Table 12A ITC availed as per audited Annual Financial Statement 400
Table 12B ITC booked in earlier Financial Years claimed in current Financial Year 0
Table 12C ITC booked in current Financial Year to be claimed in subsequent Financial Years 0
Table 12D ITC availed as per audited fnancial statements or books of account 400
Table 12E ITC claimed in Annual Return (GSTR9) 400
Note: Auditors has to cross check the GSTR-2A  of the taxpayer for any RCM liability reflected and tax is paid.

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2 Comments

  1. ASHOK KUMAR says:

    In GSTR-9C table No-12A & 12D -ITC in 12A of case No-2 you have taken ITC as per Books 7 In 12D as per GSTR-3B But in form wording is same ” ITC availed as per audited Annual Financial Statement” Not as per gstr-3B. The books of accounts audited hence in both column amount should be same

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