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Reverse-charge reporting depends on who issued the document, not simply on who pays the tax. A notified supplier’s own section 9(3) supply may require an e-invoice and IRN; the supplier’s details then flow to GSTR-1. The recipient reports the tax payable in GSTR-3B Table 3.1(d), and may report eligible credit only after payment, usually in Table 4(A)(3). Import-of-service credit is handled separately in Table 4(A)(2) and is not included in the regular reverse-charge section of GSTR-2B. Certain supplies from unregistered Indian suppliers and overseas service providers instead involve recipient-issued self-invoices.
Start by identifying the transaction and the invoice issuer
Before entering anything in a return, establish four facts: whether the supply is actually notified for reverse charge, whether the supplier is registered and covered by the current e-invoice mandate, who must issue the invoice or other document, and whether the transaction is a domestic supply or an import of services. The reporting path changes with each answer.
This guide explains the reporting workflow. It does not decide whether a particular supply falls under section 9(3), whether a supplier is currently within the e-invoice threshold or exemption rules, or whether input tax credit (ITC) is legally available. Those conclusions require the applicable notifications, the parties’ facts and the GST law in force for the relevant tax period.
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Three common documentation patterns
| Situation | Who issues the primary document? | Where the reporting handoff occurs |
|---|---|---|
| A notified registered supplier makes its own supply that attracts reverse charge under section 9(3) | The supplier issues the invoice and, if covered, reports it to the Invoice Registration Portal (IRP) | Supplier checks GSTR-1; recipient reports liability in GSTR-3B |
| A registered recipient procures a covered supply from an unregistered person located in India | The recipient may have to raise a self-invoice under the applicable rules | Recipient reports the document and reverse-charge liability in the relevant returns |
| A registered recipient receives a covered service from a person located outside India | The recipient documents the import-of-service transaction, including any required self-invoice | Recipient reports liability in GSTR-3B; import-of-service credit follows a separate table treatment |
Do not treat every reverse-charge purchase as a self-invoice case. A normal invoice from a registered supplier remains a supplier-issued document, even though the recipient pays the GST.
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When does an RCM invoice need an IRN?
The GST e-Invoice System FAQ states: “If the invoice issued by notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is applicable.” In practical terms, a notified person’s own invoice can require e-invoicing even when the customer, rather than the supplier, discharges the tax under reverse charge. The FAQ uses a notified law firm supplying a company that pays tax under reverse charge as its example.
Applicability still depends on the supplier’s current notification coverage, turnover or other prescribed criteria, exemptions and the transaction’s facts. Confirm the position for the tax period instead of assuming that every supplier or every RCM category requires an IRN.
Cases that do not use the supplier e-invoice route
The same FAQ distinguishes supplies received from an unregistered person and imports of services. In those cases, there is no supplier-issued e-invoice to report to the IRP in the ordinary sense. The recipient’s documentation and return entries must be handled under the rules applicable to that transaction.
Supplier workflow: report the invoice to the IRP and verify GSTR-1
1. Prepare the correct supplier invoice
The supplier should issue the invoice for its own supply with the required particulars, including whether tax is payable on reverse-charge basis. The CBIC invoice rules list reverse-charge status as invoice information. Marking the transaction as RCM does not by itself transfer the invoice-issuing obligation to the recipient.
2. Submit the document to the IRP
The IRP FAQ describes invoice, debit-note and credit-note documents issued by notified taxpayers for supplies to registered persons or for exports as within the stated e-invoice scope. On successful reporting, the system generates an Invoice Reference Number (IRN) and saves the document details in the GST System.
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Retain the signed or otherwise authenticated e-invoice and its IRN with the accounting record. The IRN is evidence that the document was reported through the prescribed system; it is not a ruling on the reverse-charge classification or the recipient’s ITC eligibility.
3. Check the supplier’s GSTR-1 auto-population
IRP-reported invoice details are designed to auto-populate the supplier’s GSTR-1 for the relevant period. Review the populated record rather than assuming that a successful IRP submission guarantees a complete return. Check the recipient GSTIN, invoice number and date, taxable value, tax fields, reverse-charge indicator and the period in which the record appears.
If the e-invoice does not auto-populate for the relevant month, the IRP FAQ instructs the registered person to fill the record manually. Investigate the cause at the same time—such as a reporting-period mismatch or a data error—so that a manual entry does not create a duplicate.
4. Treat edits as a new verification point
The GST Portal allows auto-populated e-invoice details in GSTR-1 to be edited. After an edit is saved, the displayed Source, IRN and IRN Date fields become blank. Therefore, do not use the continued display of those fields as the only proof that the filed record still matches the original IRP data. Compare the edited values with the underlying e-invoice and verify the final filed return and supporting records.
Recipient workflow: report the RCM liability in GSTR-3B
1. Reconcile the source documents before opening the return
Build a period-wise list of all reverse-charge transactions from purchase registers, expense ledgers, contracts, import documents and self-invoices where applicable. Match each item to the supplier invoice or recipient-issued document, the place and nature of supply, and the tax period. Separate registered-supplier RCM, unregistered-supplier cases and imports of services; they do not all appear in the same system statement.
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2. Enter tax payable in Table 3.1(d)
For registered-supplier reverse-charge supplies, the GST Portal maps the liability to GSTR-3B Table 3.1(d), “Inward supplies liable to reverse charge.” The portal’s guidance says that these supplies are declared in Table 3.1(d) for payment of tax.
Use any system-populated amount as a starting point, not as an automatic approval. Compare the figure with the books and the complete list of actual liabilities, including items that may not have appeared in a statement or that require manual entry. Correct tax type and amount errors before filing and retain a reconciliation showing how the reported total was derived.
3. Pay the tax before claiming related credit
Reverse-charge liability is a payment obligation. It is not converted into ITC merely because an invoice appears in a portal statement. Follow the payment and documentation requirements for the relevant tax period, then test the credit against all applicable eligibility, blocked-credit, business-use and time-limit rules.
How to report reverse-charge ITC
Registered-supplier RCM credit: Table 4(A)(3)
The GST Portal maps eligible credit for inward supplies liable to reverse charge to GSTR-3B Table 4(A)(3), after payment of the tax. The official wording is: “These supplies shall be declared in Table 3.1(d) of FORM GSTR-3B for payment of tax. Credit may be availed under Table 4(A)(3) of FORM GSTR-3B on payment of tax”.
“Eligible” is decisive. An auto-populated invoice, an IRN or a matching value in a statement does not establish ITC entitlement. Check the statutory conditions and restrictions for the recipient, including whether the expenditure is used in the course or furtherance of business and whether any blocked-credit or other restriction applies.
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Import-of-service credit: Table 4(A)(2)
For reverse charge on imported services, the related liability still goes in Table 3.1(d), but the GST Portal identifies the corresponding import-of-service credit separately in Table 4(A)(2). Do not place that credit in the registered-supplier RCM line simply because both transactions involve reverse charge.
Why GSTR-2B may not show import-of-service RCM
The GSTR-2B FAQ describes its reverse-charge section as covering supplier-declared invoices and debit notes for supplies from registered persons. It also states that import-of-service reverse-charge credit is not part of that statement. Consequently, absence from GSTR-2B does not by itself eliminate an import-of-service liability or prove that credit is unavailable; it means the recipient must use its own records and the applicable import documentation for reconciliation and eligibility testing.
Understanding GSTR-2B without duplicating entries
For registered-supplier RCM, use GSTR-2B as one reconciliation input. Match the reverse-charge entries to the supplier invoices, the purchase register and the amount paid in Table 3.1(d). Investigate missing, duplicated or amended records before filing.
- Do not pay only the amount displayed in GSTR-2B if your books show additional reverse-charge supplies.
- Do not claim the same credit once from a reverse-charge entry and again through another credit category.
- Do not treat a supplier’s auto-populated record as proof that every legal ITC condition has been met.
- Keep import-of-service calculations outside the assumption that GSTR-2B will provide a complete RCM listing.
Self-invoicing: the separate recipient-issued document
The CBIC sectoral FAQ says that a registered recipient procuring covered goods or services from an unregistered supplier located in India, or services from a person located outside India, is required to raise a self-invoice. It also says the invoice, debit note or credit note should be reported in the GST return for the month in which the supply takes place.
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Information to preserve with a self-invoice file
- Supplier or overseas provider identity and registration status, where relevant.
- Description, value, date and nature of the supply.
- Evidence supporting the place-of-supply and import or domestic classification.
- Reverse-charge calculation and the GSTR-3B period in which liability was reported.
- Payment records and the basis for any subsequent ITC claim.
Correcting a missing or wrong supplier record
Use GSTR-1A when the facility and timing apply
GSTR-1A is an optional GST Portal facility to add or amend records for the same period after GSTR-1 has been filed, or after its due date if that is later, and before the GSTR-3B for that period is filed. The portal guidance says the changes flow to GSTR-3B and that GSTR-1A can be filed once for a period.
- Compare the invoice, IRP record and filed GSTR-1 to identify the exact omission or error.
- Open the relevant period and use the GSTR-1A facility if it is available for that period.
- Add or amend only the affected record; check that the correction does not duplicate an existing invoice.
- Review the resulting liability and credit data before filing GSTR-3B.
- Save the acknowledgement and retain the correction trail with the invoice file.
Because portal facilities and deadlines can change, confirm that GSTR-1A is available and that its timing rules apply to the return period concerned. If the window is unavailable, follow the correction mechanism prescribed for that period rather than forcing an entry into a later return.
Practical month-end checklist
- Classify each transaction as registered-supplier RCM, specified unregistered-supplier RCM or import of services.
- Confirm the supplier’s current e-invoice coverage before deciding whether an IRN is required.
- For a covered supplier-issued invoice, verify IRP success, IRN, recipient details and GSTR-1 appearance.
- If GSTR-1 is missing the record, investigate and enter it manually when appropriate; prevent duplicates.
- Review any GSTR-1 edit because Source, IRN and IRN Date display fields clear after saving an edit.
- Reconcile GSTR-2B with books for registered-supplier RCM and separately list import-of-service transactions.
- Report all RCM tax payable in GSTR-3B Table 3.1(d), including liabilities not supplied by a statement.
- After payment, assess credit eligibility and use Table 4(A)(3) for eligible registered-supplier RCM credit.
- Use Table 4(A)(2) for eligible import-of-service credit, subject to the same legal review.
- Check whether a self-invoice is required for an unregistered Indian supplier or overseas service provider, and verify the current reporting period rule.
- File any available GSTR-1A correction before the relevant GSTR-3B and only once for that period.
- Archive invoices, self-invoices, IRNs, reconciliations, payment evidence and return acknowledgements.
Common errors and how to avoid them
Assuming the recipient never needs an IRN
The recipient pays the RCM tax, but the notified supplier may still have to e-invoice its own supply. Determine the issuer and the supplier’s mandate coverage separately from the tax-payment responsibility.
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Putting liability only in a credit table
Credit reporting does not replace payment. Enter the liability in Table 3.1(d), pay it, and then consider the appropriate credit table.
Using Table 4(A)(3) for imported services
Import-of-service credit has the distinct Table 4(A)(2) treatment identified by the portal. Keep the liability in Table 3.1(d) and document the import outside the regular GSTR-2B RCM assumption.
Claiming credit because a system populated it
System population supports reconciliation; it does not decide statutory eligibility. Apply the relevant ITC conditions and restrictions to every claim.
Creating a self-invoice for every RCM invoice
Self-invoicing is a separate documentation requirement for specified unregistered-supplier and overseas-service cases. A registered supplier’s own invoice remains the supplier’s document unless the law for the particular supply says otherwise.
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A defensible file links the underlying supply to the invoice or self-invoice, the IRP record where applicable, the supplier’s GSTR-1 entry, the recipient’s GSTR-2B reconciliation, the Table 3.1(d) liability, the tax payment and any eligible Table 4(A)(3) or 4(A)(2) credit. That chain lets an accounts reviewer explain both system-populated values and manual exceptions without treating portal data as a substitute for the legal analysis.
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