ITC REVERSAL QUERY ??

For FY 2018-19 changes were allowed to be made in GST returns upto March 2019. Therefore, if reversed once no requirement to reverse again and no DRC-03 is required. Disclose in GSTR 9 of 18-19 correctly. 

The explanation could be provided for any information requested by the department.

Yes For FY17-18, Changes were allowed upto March-19 which I did as well. But I forgot to mention the same in GSTR9 of FY17-18.

As a result, it stands as a liability in Table 8D of GSTR9 of FY17-18.

So here I have to pay it via DRC.

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Now what about the reversal I made in March-19?

Did I reverse my genuine ITC pertaining to FY18-19 ???

Part V of GSTR 9 - is a disclosure mechanism only, if it was not disclosed there it does not become a liability. 

Table 8D - Again only a disclosure mechanism, does not amount to tax payable directly. 

In GSTR 9 of FY 18-19 consider as reversal and go ahead. Interest may be applicable for delay in reversal.

Originally posted by : Utsav Patel
	I took ITC claim of Rs.904 in FY2017-18. Though it was ineligible but I was not aware of it. As a result, I didn't report the same in GSTR9 of FY2017-18. Later I realised it and reversed it in GSTR3B of March-2019. As I didn't mention about it in GSTR9 of FY2017-18, IS IT TRUE THAT I HAVE TO PAY THE SAME VIA DRC-03 FOR FY2017-18  ?? If I have to pay it via DRC03 for FY2017-18, What should I do about the Reversal which I made in GSTR3B of March-2019 ? ( Should I believe here that I accidentally REVERSE the GENUINE ITC of FY2018-19 ??)

See reversal is made in 18-19 so it would disclose a reversal in 18-19 u shall disclose these reversal in reconciliation of 18-19 as pertaining to 17-18 matter gets sorted .

I believe interest on such reversal is paid in cash.

It would b a reconciliation item in 18-19 i.e. excess cash paid and ITC reversal.

I believe even paying through DRC -03 is also not possible for fy 17-18 now unless you have failed to file annual return

dear heet

DRC-03 can always be filed. The question in the start says not mentioned in GSTR 9 of FY17-18 which indicates it was filed. Being professionals we should strive to guide people in the right direction. 

But payment through drc03 would not be disclosed in any returns in that case . Further since returns are already filed these seems an appropriate solution . Isn't it?

DRC-03 can be utilised for any payments not made. It is a voluntary payment. You may choose to pay with Cash or Credit. It can be paid even for a past period. DRC-03 does not reflect in any GST returns, therefore, would ideally be a reason for difference while filing the GSTR 9C wherein, the comment can be provided that differential tax was paid through DRC-03. In my view, any additional liability missed during 9 & 9C for a FY, can be paid through DRC-03 if identified by the assessee - anytime before being subjected to Departmental Audit/SCN. 

Originally posted by : CA Akshay Hiregange
	Part V of GSTR 9 - is a disclosure mechanism only, if it was not disclosed there it does not become a liability.  Table 8D - Again only a disclosure mechanism, does not amount to tax payable directly.  In GSTR 9 of FY 18-19 consider as reversal and go ahead. Interest may be applicable for delay in reversal.

I believe to said the same except not in technical terms.

Yes I did not comment for repeating my analysis.

It was for - "I believe even paying through DRC -03 is also not possible for fy 17-18 now unless you have failed to file annual return" which didn't seem accurate. 

Originally posted by : CA Akshay Hiregange
	Yes I did not comment for repeating my analysis. It was for - "I believe even paying through DRC -03 is also not possible for fy 17-18 now unless you have failed to file annual return" which didn't seem accurate.

So even if portal enable us to pay through DRC-03 one should not pay through drc-03 for 17-18 nyways.

Correct me if m going wrong.

Learning is part and parcel of profession

No. In my view, any liability for a FY after the time limits specific under section 39, can be discharged through DRC-03.

Example - FY 2019-20 time limit to make adjustments in GSTR 3B was September 2020 3B due date, i.e. 20th October 2020. Therefore, any liability which is being discharged for FY 2019-20 is to be considered through DRC-03. Option to utilise ITC would also be available. (this is due to certain interpretations, which department may dispute).

No time limit mentioned against DRC-03 filing. The only situtation where different form is to be utilised for payment maybe when assessee is under departmental audit, or payment against SCN.