The Govt. has introduced DRC-03A on the GST Portal – A chance to adjust unresolved/pending demands and payments.
If you have been issued any demands on the GST Portal and the same is paid through DRC-03 there are chances that the demand is still showing in the GST Electronic Liability register and is still unresolved. There are chances you may be issued a notice for the payment of the demand again.
To resolve this issue the CBIC has come out with a new form DRC-03A to help adjust the unresolved demands and the against the payments already made for them.
Q. What is form DRC-03A?
A. Form DRC-03A is a form introduced to adjust payments made through DRC-03 against any outstanding demands showing in the electronic liability register. All payments made through DRC-03 against the demands can be adjusted and the demands can be removed from the electronic liability register by filing DRC-03A.
Q. Who can file DRC-03A?
A. Taxpayers against whom demand is raised in Form GST DRC 07/DRC 08/MOV 9/MOV 11/APL 04 and for which the payment has been done through Form GST DRC-03 under ‘Voluntary’ or ‘Others’ categories can file Form GST DRC-03A.
Q. Where is form DRC-03A available for filing?
A. DRC-03A is available for filing on the GST common Portal under the following Tabs:
Services > User Services > My Applications> Form GST DRC 03A.
Then click on the new application and start filing DRC-03A.
Q. What details do taxpayers need to enter while filing Form GST DRC03A?
A. Taxpayers need to enter the ARN of Form GST DRC-03 and the demand order number is to be selected using a drop-down. The details of the demand outstanding against the order and the payment done through FORM GST DRC-03 will be displayed. As soon as these are displayed the taxpayers can click on ‘adjustment of demand‘ Tab and adjust payment made in DRC-03 against the said demand order.
Q. Can a taxpayer use multiple Form GST DRC-03s to adjust a single demand and vice-versa?
A. Yes, a taxpayer can adjust multiple Form GST DRC-03s against a single demand order. The taxpayer has to file separate DRC-03A for each DRC-03 if multiple DRC-03 are to be adjusted against a single demand order.
As soon as you use one DRC-03 against the order, the outstanding demand displayed against the order will be reduced by the amount of DRC- 03 adjusted against the demand order and the same goes on till the amount against the demand is zero, if the whole of the demand is paid through DRC-03.
Also, a single Form GST DRC-03 can also be used for adjustment against multiple demand orders.
Q. Can all DRC-03s be adjusted against the demand orders?
A. No, only the DRC-03 for which the payment has been done under ‘Voluntary’ or ‘Others’ categories can be adjusted against Form GST DRC-03A.
Q. Can DRC-03s and order for all financial years be adjusted against DRC-03A?
A. Yes, it seems that this adjustment of demand in DRC-03A can be done for all financial years provided order/demand in form GST DRC 07/DRC 08/MOV 9/MOV 11/APL 04 has been issued.
Q. Will the amount paid by cash ledger and Credit ledger in DRC-03 be adjusted separately?
A. The amount paid through Cash and credit ledgers in DRC-03 will be adjusted separately in form DRC-03A.
Q. Why was form DRC-03A introduced?
A. It was observed that some taxpayers had paid the amount demanded vide DRC 07/DRC 08/MOV 09/MOV 11/APL 04 through DRC-03 instead of using payment facility ‘Payment towards demand’ available on GST portal. This happened as the facilities on the portal were new and the taxpayers did not know the exact method for payments of demand especially in case of assessment and appeals for the FY 2017-18 to 2019-20. This led to a situation where the demand has been paid by the taxpayer, however the demand is not closed in the electronic liability register. To address this issue, the government has notified a new form named GST DRC-03A which vide Notification No. 12/2024 dated. 10th July 2024 which has now been made live on the portal for the adjustment of such unadjusted demands.
Q. What if wrong information is provided in DRC-03A?
A. If a taxpayer provides wrong information or adjusts the DRC-03 which was not meant for the payment of said demand. The taxpayer will be liable to pay the amount along with interest and penal action can also taken u/s 122 (1)(x) of the CGST Act.
Note: Another major advantage of Form DRC-03A could be is its role in handling pre-deposit requirements for appeals. Taxpayers who have made payments via DRC-03 can use DRC-03A to show that the payment was made against a particular demand. This is particularly useful when filing GST appeals before the GST Tribunal, as it provides clear evidence that the requirement of pre-deposit has been satisfied.
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(The author is a Chartered Accountant and can be contacted at [email protected] or [email protected] or Mobile: +91-9953199493)
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