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RCM Self Invoice and Blocked ITC (17(5))

1. RCM Self Invoice (Rule 47A)

When you buy goods or services from an unregistered supplier on which you pay GST under reverse charge, or you import services, the law (section 31(3)(f) of the CGST Act read with Rule 47A) requires you to issue a tax invoice to yourself, within 30 days of receiving the supply.

Open Accounts > RCM Self Invoice (or ask your administrator to grant the rcmselfinv right) and click Add.

Field What to enter
Self Invoice No. / Date Auto number; date of issue
Supplier The unregistered supplier (or foreign supplier). GSTIN, Place of Supply and Import of Services fill in from the ledger
Goods/Services SERVICES or GOODS
Date of Receipt of Supply Date the goods / service were received (the 30-day clock starts here)
Supplier Bill / Voucher No, Date The supplier's bill or your voucher reference
Grid Description, HSN/SAC, Qty, Unit, Rate, GST % - Taxable, GST Amt and Amount work out by themselves (for a lump-sum service leave Qty / Rate blank and type the Taxable Value)

On Save the ERP re-works every row and splits the tax into IGST or CGST + SGST the same way GSTR-3B does (supplier's state against your GSTIN state; import of services is always IGST). It refuses to save without a supplier, a description, a taxable value or a GST %.

If you pick a supplier who has a valid 15-character GSTIN, the screen warns you: notified RCM services from a registered supplier (GTA, advocate, etc.) are invoiced by the supplier, so no self invoice is needed.

Print gives an A4 self invoice with your logo, the supplier details, items, the tax split, amount in words and the declaration "Tax payable on reverse charge: YES".

The self invoice is a document only. The RCM tax itself is still reported in GSTR-3B 3.1(d) and 4(A)(2)/(3) from the purchase / expense entry marked Rev.Ch = Y, so nothing is counted twice.


2. Blocked ITC under section 17(5)

Bank, Cash, Journal and Sale-Journal voucher grids and Gen.Expense now have a Blocked ITC 17(5) column (N / Y). Mark it Y on rows whose GST is not allowed as credit, for example motor vehicles, food and beverages, club membership, works contract for immovable property or goods given as gifts.

The GST of those rows stays in GSTR-3B 4(A) ITC Available and is shown again in 4(B)(1) As per rules 38, 42 & 43 of CGST Rules and section 17(5), so 4(C) Net ITC Available is reduced by it. Click the 4(B)(1) row to see the list of blocked entries.


3. GSTR-3B changes in this release

  • Table 4 labels follow the current GSTN form: 4(B)(1) rules 38, 42, 43 & section 17(5); 4(D)(1) ITC reclaimed which was reversed under 4(B)(2) earlier; 4(D)(2) ineligible ITC under section 16(4) / PoS rules.
  • Table 6.1 Tax Paid in Cash is now the tax payable less Net ITC 4(C), so ITC reversed in 4(B)(1) and 4(B)(2) correctly increases the cash payable. Before, 6.1 ignored the reversals.