To, ‘The Deputy Commissioner- Sector-18, o7/u12024 State GST Office, Lucknow (C) II, UP Ref: GSTIN: 09AAGCS4852H1Z2 M/s. Shakshi Coir Products Pvt Ltd 127, NH 30, Bachhrawan, Raebareli UP-229301 Sub: Application U/s 161 of CGST Act for rectification of Errors apparent on the face_of record for DRC-07 order dated 12/08/2024 _having_reference_no. Z1D090824084407X for the F.Y-2019-20. Sir, Kindly refer to the order passed under section 73(9) dated 12-08-2024 having DIN Z1D090824084407X for F.Y. 2019-20. Sir, we would like to explain you that our reply was not filed due to technical glitches of GST PORTAL which was not allowed us to upload reply after allowing an adjournment for 7days (ie. 01/07/2024 to 08/07/2024) under DRC-01. We also visited jurisdictional office Sector -18 State GST Office, Lucknow (C ) Il, UP, but they had not accepted hard copy of reply and documents however, they advised us to raise grievance on portal as this error is being face by so many taxpayers for the said tax period. Therefore, we had lodge grievance on GST PORTAL Vide ticket no, G-202407050351714 dated:05/07/2024 but no response was received from there and we had further lodged grievance vide ticket no. G-202408060464814 dated 06/08/2024 and waiting for solution but in the mean time we had received an order u/s 73(9) under form DRC-07.We had finalized our tax and compiled the documents, supporting evidences and certificates for uploading it on dated 02/07/2024 therefore we had paid tax on dated 02/07/2024 under IGST Rs. 1,39,511.00, CGST Rs. 34,308.00 and SGST Rs. 34,308.00 vide form DRC-03 having ARN AD090724003080). Sir, you had not consider the tax paid challan DRC-03, ITC reflected of those suppliers which were late filed but allowed as per 53 GST Council meeting and some ITC related with FY. 18-19 which was claimed in GSTR 3-B of F.Y 2019-20 due to receive of goods in April 2019. We are praying to consider our explanation and evidences against all the points mentioned in order DRC-07 and requesting for rectification of the order passed by you under form DRC-07. In reference to the same I would like to submit as below. 1. That wart. point 1 of the notice, for the difference of excess ITC Claimed in GSTR-3B over GSTR-2A, we would like to submit - That the ITC Credit claimed in GSTR-3B as per Invoices and Goods Received and the payment for said invoices were made within 180 days from the date of Invoice as per section 16(2) (C). The updated GSTR-2A is downloaded in which supplier has filed the Invoices and debit notes in its GSTR-1 Returns. However, some of the suppliers filed its returns beyond the period specified, due to which it was not showing on GSTR-2A Comparison Chart. Although the details are reflecting in monthly GSTR-2A Returns and for the same tax has been paid through GSTR-3B Returns,‘TaxPeriod _1TCclaimed in GSTR-38 ring the month [as pr table ‘2n(a)+4(5)-48(4)-4802)1* est cost sost/uTest cess ports 167448000 111568200 14as.e200 00 Meyi# 97871400 16,7559.00 60755900 0.00 duis 125106400 63269500 63263500 0.00 dis 49096700 4357000 49387000 0.00 aug 600600 4.262000 43642000 © 000 seri? 1198069.90 90300500 920500 © aco Nori 15590400 1,742750031,7437800 «aan Dect9 1690.25.00 109654600 109654600 0.00 vana0 149298200 95507700 985077000) Feb2020S6s61.00 123628100 2362800 Merad 1546.58.00 98222300 senazn00 © 000 otal 183,14733.00 1, 27600 1,12,66,27600 {TC auto- drafted in GSTR-2A during the month [2 pr! 'PART-B](Excuding RM supplies) est cost sost/urest 7791329 szstsesaz 3549652 series 477015 a7a7m03 mwas — 9.sgoisa2—9ssoisaz tasaasns2—68aus? 640487 risrasear —2a34B904 121343804 woranay eases Bsets on 0.00 1,77,1799271 41231,96807 132, We take Screen Shot of GSTR-2A comparison Chart which are showing latest position of ITC updated. However, the table-8A ITC got freeze and not updating further, Therefore, we taken ITC as per GSTR-2A comparison Sheet for calculating difference between GSTR-3B & GSTR-2A. The correct difference between GSTR-2A and GSTR-3B is identified as per below table: SI | ISSUE IGST CGST SGST TOTAL No. 1. [ITC as per 2-A| 1771799271 | 11231968.07 | 11231968.07 | 40181928.85 ‘Comparison Chart 2 ITC Claimed in | 18314733,00 | 11266276.00 | 11266276.00 | 40847285.00 GSTR3BExcess 1Tc claimed in GSTR- 3B (a) 596740.29 34307.93 34307.93 (665356.15 ITC related with FY 1849 but claimed in F.Y 19- 20 in April 2019 for which March 2019 GSTR-2A is attached (B) 146336.71 0.00 0.00 146336.71 TTC claimed as per Invoice but GSTR- 3B filed ~~ by suppliers beyond the due date for which we also produced Certificates, Invoice (As_per GST Council Meeting held on the; have recommended that the to avail input tax credit_w.r.t any Invoice or debit e Limit 310893.46 0.00 0.00 310893.46note under section 16 (4) of cGsT Act, throu; an} GSTR-3B_return filed upto 30/11/2021 for EY 2017-18, 2018-19, 2019-20 and_2020- 21__may be deemed to _be soyiy2021") (C ) Net Difference | 139510.12 34307.93 34307.93 208125.98 (A-B-C) ‘The difference related to excess ITC claimed is identified and explained with two reasons: a) ITC related with F.Y 18-19 but claimed in F.Y 19-20 b) IC claimed as per Invoice but GSTR-3B filed by suppliers beyond the due date specified. The Net difference as calculated above is explained as per “Annexure-1” and the excess ITC claimed is deposited through DRC-03 Challan dated 02/07/2024 vide ARN-AD090724003080J. That w.x.t point no.2 which required clarification on credit notes reported in column - 4(1)/(J) of GSTR -9,, we would like to submit that credit note and debit note issued to buyers against return of goods, rate variance and defect in goods etc. The summary of Credit note is being attached. We also provide sample of credit note issued by us. As per Annexure-2That w.r-t point no.3 which required explanation on differences arises between EWB Outward sale and GSTR-3B of Rs.12,20,991.00, we would like to submit the Reconciliation Statement and other supporting documents that will mitigate the said differences. We also attached Month Wise Turnover sheet as per GSTR-1 & GSTR-SB. Point No.3 : E- WAY BILL RECONCILAITION Particulars Amount Remarks ‘Turnover as per EWB Outward 294,462,581.66 Credit Note issued against sale which reduces GSTR-1 & GSTR-3B As per Turnover but not reduces EWB Annexure Less: | turnover 971,999.71 2 Debit note issued against sale which increases GSTR-1 & GSTR-3B As per Turnover but not increased EWB Annexure add: | Turnover 38,078.89 | (883920.82) | -2 As per Less Annexure : | Stock Transfer through E way bill 740,581.10 3 but not consider in sale reported for GSTR-1 & GSTR-3B As per Annexure ‘Add: | Local Sale without E way bill 403,510.26 4 Turnover as per GSTR 3B 293,241,590.00 4, That w.x.t point no in which explanation asked about Column 5-(A) of GSTR-9, zero rated supply (export) without payment of Tax of Rs.16398882.70. We would like tosubmit that the export was made after filing of LUT, which enable us to export of goods to a country outside India without payment of IGST, the copy of the same is also attached along with Invoices. The Invoice wise details are as under: EXPORT SALES 41-Apr-19 to 34-Mar-20 ‘CUSTOMER NAME BILLNO. “Amount EWay bill DATE E-Way bill no. | date ‘O1-Apr- | BNRS Trading LIGA/c (NEPAL) 2018207 | 319807.00 19 451058478604 | 01/04/2019 ‘5-Apr- | BNRS Trading LICA/c (NEPAL) 2019-202 | 362726.00 19 431059383822 | 06/04/2019 ‘20-May- | GORIL TRADE 2019-2073 | 680167.00 19 | CONCERN.LIGA/o(NEPAL) 401066781180 | 20/05/2019 2éMay- | ANT Intemational Pvt. Lid. 2019-2074 | 654000.00 19 451068007203 | 27/05/2019 TO-Jun- | GORIL TRADE 2018-2015 | 303046.00 18 | CONCERN.LIGA/C(NEPAL) 471070151086 | 10/06/2019 un- | GORIL TRADE. 2019-2016 | — 625361.00 18 | CONCERN.UCAc(NEPAL) 481070909082 | 14/06/2019 ¥2Juk | ANT International Pvt. Lid. 2019-2077 | 681429.50 19 481075678749 |_ 15/07/2019 (2-Aug- | BNRS Trading LICAIc (NEPAL) 2019-2078 | — 308734.00 18 431079027869 | 06/08/2019 ‘¥6-Aug- | GORIL TRADE 2019-209 | — 878025.00 19 | CONCERN.LICA/o(NEPAL) 451080759379 | 19/08/2019 30-Aug- | R.O.K. Product Industries Pvt. Ltd. 2019-20710 | 623566.70 19 451083059065 | 02/09/2019 ‘09-Sep- | GORIL TRADE 2018-2011 | 903677.00 418 | CONCERN.UIGA/c(NEPAL) 431084610191 | 12/09/2019 72a-Sep- | BNRS Trading LICAIc (NEPAL) 2019-20712 | 334287.00 19 431086472049 |_ 24/09/2019 24-Sep- | Mis Palpa Bhairab Mulli Supplier & Traders | _ 2019-20713 | 768344.00 19 | Pttd | 471087107481 | 27/09/2019 08-0c- [R.O.K. Product Industries Pvt. Lid. 2018-20714 | — 69254640 18 401089062455 | 10/10/2019 18-Oci- | GORIL TRADE ‘2019-20715 | 659080.00 19 | CONCERN.UCA/c(NEPAL) 401090711968 | 19/10/2019 TNov- | R.O.K Product Industries Pvt. Ltd 209-2076 | 675540.84 19 451094178841 | 11/11/2019 TENov- | ROK Product Industries Pvt. Ltd 2018-20117 | 2400.00 L_19 401094180416 | 11/11/2019 ‘20-Nov- | GORIL TRADE 2ove-20718 | 95848600 19 | CONCERN.UIGA/C(NEPAL) 411095662479 |_ 20/11/2019 ‘20-Nov- | BNRS Trading LICAlc (NEPAL) 2018-2078 | 326805.00 19 411095749305 |_ 20/11/2019 TDec- | ROK. Product Industries Pvt. Lid 2019-20720 | 518305.08 19 441100065786 | 17/12/201917-De0- Ltd. 2012021 | 168637. 1 [oceans eee 5° | qarnoo067127 |_ 7/12/2019 ‘31-Dec- | GORIL TRADE -2019-20/22 839153.00 19 | CONCERN.UCA/c(NEPAL) 421102247683 | 31/12/2019 ‘T3-Jan- [Mis Palpa Bhairab Muli Supplier & Traders | 20702023 | —aT0275.00 20 | PvtLtd 421102732473 | 03/01/2020 2Jan- Product Ti Prt Ud WISDO2 | S7ABTEBA 70 | SOK "exc 411105482501 |_ 21/01/2020 24-Jan- | M/s. Rehan Phaibar Stc 2019-20725 +276588.00 2 ee 491106062054 | 24/01/2020 13-Feb- | BNRS Trading LCA/c (NEPAL) 2019-20/26 363925.00 20. ee PAY : 451109743646 | 14/02/2020 2OFeb- |ROK Product Indushies Pvt Lid BISDORT | —G00S46.A0 20. 471111141032 | 22/02/2020 27-Feb- | GORIL TRADE 2019-20/28- 768069.00 20 | CONCERN.L/CA/c(NEPAL) 491112679736 | 01/03/2020 Filia | GORIL TRADE ISD} — 919528.00 20 | CONCERN.UCA/o(NEPAL) 491115884296 | 21/03/2020 TOTAL | 16398882.26 We also attached Sample Invoices for your reference. As per Annexure -5 We are praying your good self, kindly waive the penalty levied in Form DRC-01. As ‘The Gst Council also recommended for waiver of penalty in its 53 Meeting. “GST Council Recommends waiving interest and penalties for demand notices issued_under_section 73 of CGST Act (ie. the cases not involving fraud, ‘Suppression or willful misstatement, etc) for the fiscal years 2017-18, 2018-19 and 2019-20, if the full tax demanded is paid upto 31.03.2025.” Hence, I hope the above provides enough clarity regarding the issue under consideration, and I hope that your good self would accommodate the above and may drop the scrutiny proceedings and oblige me. Yours Sincerely : St HI coup pggpucTS (P) LID. Director M/s Shakshi Coir Products Pvt Ltd (Director)