As October 31, 2024, approaches, taxpayers should note two essential Goods and Services Tax compliance deadlines — the last date to declare Opening balance in RCM Liability / ITC Statement and the last date to report opening balance in Input Tax Credit ( ITC ) Reversal Ledger.
For the reporting of Reverse Charge Mechanism (RCM) transactions, the GST Portal has introduced the “RCM Liability/ITC Statement.” This tool enhances transparency and accuracy in RCM transactions by aligning the RCM liability reported in Table 3.1(d) and its corresponding ITC in Table 4A(2) and 4A(3) of GSTR-3B for the specified return period.
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The statement is applicable from August 2024 for monthly filers and the July-September 2024 quarter for quarterly filers. To access this, go to Services > Ledgers > RCM Statement on the GST Portal.
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Reporting RCM ITC Opening Balance:
– Navigation: Follow the path Ledger > RCM Liability/ITC Statement and report any RCM ITC opening balance.
For example:
Excess Paid RCM Liability: If you have paid excess RCM liability in Table 3.1(d) of GSTR-3B but have not claimed ITC in Table 4A(2) or 4A(3), you can report this as a positive value in the RCM ITC opening balance.
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Excess Claimed RCM ITC: If you have claimed more ITC in Table 4A than the RCM liability reported, a negative value should be reported in the opening balance.
Eligible RCM ITC reversed in earlier periods may be reclaimed in Table 4A(5) of GSTR-3B if the conditions are met. Opening balances should be reported as follows:
Monthly filers: Reflect the cumulative balance as of the July 2024 return period.
Quarterly filers: Reflect the balance through Q1 of FY 2024-25 (April-June 2024).
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Key Deadlines:
Declare by: October 31, 2024.
Amendments: Errors in declared opening balances can be corrected by November 30, 2024, with up to three amendment opportunities. The amendment facility will close post-November 30.
Reporting Opening Balance in ITC Reversal Ledger
To support accurate ITC reversal reporting, the government introduced an “ITC Reversal/Reclaimed Statement” on the GST Portal. This update follows Notification No. 14/2022 (July 2022) and is effective from September 2023 for monthly and July-September 2023 for quarterly taxpayers. It enables reporting of cumulative ITC reversal and reclaim values in the opening balance.
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Period: October 15 to October 31, 2024.
Amendments: Corrections to ITC reversal opening balance must be finalised by November 30, 2024.
Instructions for Monthly and Quarterly Filers:
Monthly filers: Reflect the opening balance of ITC reversal up to July 2023.
Quarterly filers: Reflect the ITC reversal balance through Q1 of FY 2023-24 (April-June 2023).
The system will restrict the re-claiming of excess ITC beyond available balances in the Electronic Credit Reversal Ledger.
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