Credit that survives scrutiny
Credit is tested against the statutory conditions before it is claimed rather than defended after it is questioned, and the evidence sits with the claim.
Tax & Regulatory
GST Advisory & Compliance
Monthly GST compliance and the advisory positions underneath it: return preparation, GSTR-2B and Invoice Management System credit matching, place-of-supply and export testing, and the annual return and reconciliation statement.
Overview
GST exposure is rarely created at the filing stage. It is created earlier, in a customer master carrying the wrong place of supply, an invoice series that does not tie back to the ledger, or a credit claimed against a document that never appeared in GSTR-2B.
It surfaces eighteen months later as an intimation for a period the finance team closed long ago. The system has also stopped tolerating late correction. Tables 3.1 and 3.2 of GSTR-3B are populated from GSTR-1 and cannot be edited, so an outward-supply error has to be fixed through GSTR-1A. Returns become time-barred three years after their due date. Input tax credit is settled in the Invoice Management System before GSTR-2B is generated, and leaving a supplier document untouched counts as accepting it.
This engagement runs the monthly cycle and the positions underneath it: place of supply, zero-rating, reverse charge, credit eligibility, and the annual reconciliation that has to agree with your audited accounts.
Scope of engagement
- Monthly or quarterly preparation and filing of GSTR-1 and GSTR-3B, with amendments routed through GSTR-1A rather than adjusted in a later summary table.
- Invoice Management System review each period: accepting, rejecting or holding supplier documents before GSTR-2B is drawn, with a recorded reason for every rejection.
- Input tax credit testing against each condition in Section 16(2), including receipt of the goods or services, the supplier disclosure requirement in Section 16(2)(aa), and the 180-day payment condition that reverses credit where a supplier invoice remains unpaid.
- Blocked credit review under Section 17(5) and proportionate reversal under Rules 42 and 43 where exempt or non-business use exists.
- Place of supply determination under Sections 10 to 13 of the IGST Act, with Section 13 applied where the supplier or recipient is outside India.
- Export and zero-rating work: testing the Section 2(6) conditions for export of services, supply under a letter of undertaking in Form GST RFD-11, and refund claims for accumulated credit.
- Reverse charge mapping under Sections 9(3) and 9(4) of the CGST Act, including self-invoicing under Section 31(3)(f) for procurement from unregistered suppliers.
- E-invoicing and e-way bill controls: invoice reference number generation, the 30-day reporting window on the invoice registration portal that applies at and above ₹10 crore aggregate annual turnover, and the ₹50,000 consignment trigger together with the lower intra-State thresholds some States apply.
- Distribution of common input services through the Input Service Distributor mechanism where a head office receives invoices on behalf of other registrations.
- Annual return in GSTR-9 for registrations above ₹2 crore aggregate turnover, and the self-certified reconciliation statement in GSTR-9C above ₹5 crore.
- Registration amendments, additional places of business, and annual renewal of the letter of undertaking.
- Contract and rate review following the restructure of the rate schedule that took effect on 22 September 2025.
Deliverables
- A filed return set for each period with the acknowledgement and the payment challan.
- A monthly credit reconciliation running books to GSTR-2B to the action taken in the Invoice Management System, with every unmatched line carrying an owner and a reason.
- A rolling exceptions register holding disputed supplier documents, credits on hold, and reversals pending.
- An annual pack containing GSTR-9, GSTR-9C, and the reconciliation between turnover per the audited financial statements and turnover as returned.
- Dated written positions on place of supply, zero-rating and reverse charge for the transaction types you actually run, referenced to the provision relied on.
- A compliance calendar covering the entity and each State registration separately.
- A short monthly note to the Finance Director stating what changed, what was filed, and what is at risk.
Process
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Position review
We read the registrations, the customer and vendor masters, the invoice formats and the significant contracts. Most errors are structural and repeat every month, so this is where they are found.
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Baseline reconciliation
Books against GSTR-2B, GSTR-1 against GSTR-3B against the ledger, and outward supplies against revenue. Prior-period gaps are quantified and separated into what can still be corrected and what cannot.
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Control design
We set the cut-off dates, the Invoice Management System decision rules, the e-invoicing and e-way bill checks, and the escalation point for anything outside the rules. This is agreed in writing before the first filing.
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Monthly operation
Data received, credit matched, returns prepared and sent for your approval, filings made, acknowledgements returned, exceptions register updated.
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Annual close
The annual return and reconciliation statement are prepared against the audited accounts, and the differences that will need explaining later are documented while the evidence still exists.
Benefits
Errors caught inside the window
Outward-supply and credit errors are identified while GSTR-1A and the current period still allow correction, before the three-year bar removes the option.
Written positions, not habits
Place of supply, zero-rating and reverse charge treatments are recorded with reasons, so a later officer is answered from a file rather than from memory.
An annual return that ties
The reconciliation to the audited accounts is built through the year, which is why the December filing stops being an emergency.
Industries served
Manufacturing, where the work is job-work movements, e-way bill discipline across plants and depots, and credit on capital goods. Retail and e-commerce, where it is the operator collection mechanism in Section 9(5), returns and credit notes at volume, and stock transfers between State registrations. Technology and software, where it is the export-of-services conditions, the establishment question inside a group, and reverse charge on imported services. We also act for healthcare, financial services, real estate and infrastructure, and growth companies making their first multi-State filings.
Typical timeline
- Scoping call and document list: next business day after enquiry.
- Position review and baseline reconciliation: 2 to 4 weeks, depending on the number of registrations and the length of the unreconciled period.
- Control design and sign-off: 5 business days after the baseline is agreed.
- Monthly cycle from that point: data due from you by the fifth, draft returns to you by the tenth, credit action completed before GSTR-2B is generated.
- Annual return and reconciliation statement: prepared once the statutory audit is signed, filed ahead of the 31 December deadline.
Engagement model
Contracted on a monthly retainer priced by the number of GST registrations and the volume of documents, or as a fixed-fee one-off review where you want the position examined before committing to ongoing work. The scope, the registrations covered and the escalation rules are set out in an engagement letter before any filing is made.
Delivery is virtual. We work from your accounting system through read-only or restricted access, or from exports if your policy prevents that. Returns are filed from your own portal credentials, so nothing leaves your control, and each filing is sent to you for approval before it is submitted.
What is not included
- Bookkeeping. We reconcile and file from your ledger; we do not maintain it under this engagement.
- Payment of tax. We prepare the challan and tell you the amount and the date; the funds move from your account.
- Customs duty, foreign trade policy incentives, SEZ approvals, and refund claims arising under those regimes.
- Drafting replies to show cause notices and appeals. Those are separate engagements. We hand over the working papers and the reconciliation without charge if you instruct us on them.
- Appearance before the Goods and Services Tax Appellate Tribunal, the High Court or the Supreme Court.
- Legal opinions on the constitutional validity of a levy or a rule.
- Correction of periods already barred by limitation. We will quantify the exposure and set out the options, but we cannot file what the statute no longer permits.
- Configuration of your ERP or billing system. We specify what the output must contain and test it; your vendor builds it.
- Certification of turnover or credit to a bank or an investor.
Frequently asked questions
It is not claimable until it appears. Section 16(2)(aa) makes the supplier's disclosure a condition of the credit, so a purchase invoice sitting in your ledger with no corresponding entry in GSTR-2B is a receivable from the supplier, not a credit. We age these by supplier and by amount, hold them in an exceptions register, and give your team the list to chase before the supplier's own filing window closes.
Possibly. Limitation runs from the due date of the annual return for that financial year, not from the month of the transaction, and the period available to the department is longer where suppression or wilful misstatement is alleged. Periods up to FY 2023-24 are governed by Sections 73 and 74. From FY 2024-25 the department proceeds under Section 74A, which uses one notice route and settles the fraud question at adjudication rather than at drafting.
Selling into a State does not by itself create a registration obligation. Having a fixed establishment there generally does. The common triggers are a warehouse, a leased office with staff, or a site presence on a works contract. We test each location against the place-of-supply provisions and against how the contract is actually performed, because the answer follows the facts on the ground rather than the billing address.
All five conditions in Section 2(6) of the IGST Act, each of which fails independently. The supplier is in India, the recipient outside it, the place of supply outside India, payment received in convertible foreign exchange or permitted rupees, and the two parties not merely establishments of the same person. That last condition is the one that catches Indian subsidiaries billing an overseas parent. We also confirm the letter of undertaking in Form GST RFD-11 is current for the financial year.
Ours, against rules we agree with you in writing first. Accepting, rejecting or holding a document changes what enters GSTR-2B, so it is a decision with consequences and it is logged. Anything outside the agreed rules comes back to you before we act. Documents left untouched are treated as accepted when GSTR-2B is generated, so the review has to be finished before that point each month.
Not through the ordinary route. Returns are barred three years after their due date, and the portal enforces it. Where a period is already barred we deal with the consequences instead: quantifying the tax and interest, considering a voluntary payment in DRC-03, and preparing the position you will need if the department raises the period later. We will tell you plainly when a window has closed rather than attempt a filing that cannot succeed.
Reverse it in the current period with interest rather than wait to be found. The credit fails the disclosure condition regardless of whether you hold a valid tax invoice and have paid the supplier in full. We quantify the reversal, document the reason so it survives a later query, and pursue recovery from the supplier as a commercial debt. Where the supplier subsequently files, the credit can be reclaimed subject to the time limits.
Related services
Tax Notice & Assessment Representation
For the intimation or show cause notice that arrives for a period this engagement is now reconciling.
Data Reconciliation Services
Where the underlying ledger and the returns have diverged over several years and the gap has to be rebuilt first.
Virtual CFO Services
Where indirect tax is one part of a finance function that needs running rather than a standalone compliance need.