Advisory on GST and Pre-Arbitration Steps Compliance
Advisory on introduction of Reverse Charge Mechanism (RCM) Liability / Input Tax Credit (ITC) statement. The GST portal has introduced significant changes to improve compliance accuracy and transparency. These updates also align with broader regulatory processes, including pre-arbitration steps that ensure proper dispute resolution under Indian law.
Reverse Charge Mechanism (RCM) Liability and ITC Statement
To enhance the accuracy and transparency of RCM transactions, a new statement has been introduced on the GST Advisory and Compliance portal.
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This statement applies from August 2024 for monthly filers.
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For quarterly filers, it applies from July–September 2024.
Navigation to Access Statement:
The statement can be accessed using the navigation:
Services >> Ledger >> RCM Liability/ITC Statement.
Reporting Opening Balance in RCM ITC Statement
Login >> Report RCM ITC Opening Balance or Services
OR
Ledger >> RCM Liability/ITC Statement >> Report RCM ITC Opening Balance
Key Reporting Guidelines:
Taxpayers need to fill positive values in opening balance if liability is already declared even so ITC is not claimed. Further negative values are to be reported in vice-versa cases. To reclaim the RCM already reversed in previous tax period, the opening balance needs to be reported in RCM ITC Statement.
Important Deadlines:
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Reconciliation is required till July 2024 (monthly filers) and Q1 April–June (quarterly filers).
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Reporting must be completed by 31.10.2024.
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Taxpayers will get three amendment opportunities till 30.11.2024. After this, the facility will be discontinued.
Furnishing Bank Account Details under GST Advisory
As per Rule 10A, every taxpayer must furnish valid bank account details:
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Within 30 days from registration, or
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At the time of furnishing outward supplies, whichever is earlier.
From 1st September 2024, taxpayers cannot furnish outward supply details without valid bank details.
Navigation to Furnish Bank Details:
Services >> Registration >> Amendment of Registration (Non-Core Fields)
Pre-Arbitration Steps and Legal Relevance
Although this GST tax advisory primarily addresses tax compliance, it reflects the structured approach also seen in dispute resolution law. Courts, including the Delhi High Court arbitration judgment, emphasize compliance with mandatory pre-arbitration procedures under Arbitration and Conciliation Act Section 11(6).
Only when such pre-arbitration steps fail can parties seek the appointment of an arbitrator in India. For instance, Clause 26 arbitration dispute resolution in contracts outlines structured stages before disputes move to arbitration.
This parallel highlights the importance of following both tax compliance procedures and mandatory pre-arbitration steps for legal enforceability.