ROCK & ROLL BROS
36/2, BHARATHIAR STREET, MANIYAKARAMPALAYAM ROAD,
GANAPATHY, COIMBATORE - 641006, TAMIL NADU (State Code: 33)
GSTIN: 33AAWFR0920L1ZW
May 15, 2025
To
The Deputy Commercial Tax Officer,
Saravanampatti (West) Circle,
Coimbatore.
Dear Sir/Madam,
Sub: Reply to Intimation issued in Form DRC-01A – Reg
Ref: Your notice issued in Form DRC-01A vide reference no.: ZD330525007629D/2021-
22 dated 02/05/2025 against GSTIN: 33AAWFR0920L1ZW
Regarding the notice issued to us as cited above, we kindly submit for your consideration the
following:
(1)Reconciliation of E-waybill turnover with GSTR-1:
Regarding the defect of non-reconciliation of E-waybill turnover with GSTR-1 turnover, since
our GSTIN stands cancelled, we are unable to download summary of E-waybills from the
portal and we are compiling the records available with us for the reconciliation with GSTR1
returns. Therefore, we request you to grant an additional time of 15 working days to provide
a detailed reconciliation of GSTR1 & E-waybill.
(2)Excess claim of ITC in GSTR-3B w.r.t GSTR-9:
The alleged defect of excess claim of ITC in GSTR-3B is erroneous, as the difference in Table
6J of GSTR-9 is merely the value of ITC which was reversed under Table 4B (2) of GSTR-3B
for FY 2021-22. We herewith attach the consolidated GSTR-3B summary in contention in
this regard. We have disclosed the value of net input tax credit claimed in the GSTR-3B
returns in table 6I of GSTR-3B. Therefore, there is no excess claim of ITC w.r.t to GSTR-3B &
GSTR-9. Hence, we kindly request you to drop further proceedings in this regard.
(3) ITC to be reversed on non-business transactions & Exempt Supplies:
The exempt supplies declared in Table 5 of GSTR-9 consists of the following:
S. No Particulars Amount (Rs.)
1 Discount Received through commercial credit notes 5,60,331
2 Chit Dividend Income 67,000
3 TOTAL 6,27,331
As per Explanation 1 of Rule 43, “For the purposes of rule 42 and this rule, it is hereby clarified
that the aggregate value of exempt supplies shall exclude: -
(a) [****] (Omitted)
(b) the value of services by way of accepting deposits, extending loans or advances in so far as
the consideration is represented by way of interest or discount, except in case of a banking
ROCK & ROLL BROS
36/2, BHARATHIAR STREET, MANIYAKARAMPALAYAM ROAD,
GANAPATHY, COIMBATORE - 641006, TAMIL NADU (State Code: 33)
GSTIN: 33AAWFR0920L1ZW
company or a financial institution including a non-banking financial company, engaged in
supplying services by way of accepting deposits, extending loans or advances.”
Further, we wish to bring to your consideration the Circular No. 92/11/2019-GST which
states “It is hereby clarified that financial / commercial credit note(s) can be issued by the
supplier even if the conditions mentioned in clause (b) of sub-section (3) of section 15 of the
said Act are not satisfied. In other words, credit note(s) can be issued as a commercial
transaction between the two contracting parties.”
(4)Interest in Invoice Value increased through amendments:
We hereby agree to pay the Interest of Rs. 22/- (CGST/SGST – Rs.11/each) arising from
upward amendments of GSTR-1 for the FY 2021-22 through DRC-03 & the same shall be
submitted as additional information of this notice.
(5) GSTR-1 Late Fees:
We hereby agree to pay the Late Fees of Rs. 300/- (CGST/SGST – Rs. 150/each) arising from
delayed filing of GSTR-1 for the FY 2021-22 through DRC-03 & the same shall be submitted
as additional information of this notice.
(6) GSTR-9/9C Late Fees
We wish to bring to your attention that our aggregate annual turnover for the FY 2021-22 is
Rs. 1,89,01,944/- which is well within the limits of Rs. 2 Crores which was specified for
mandatory filing of annual return u/s. 44 of the CGST Act, 2017.
Although filing GSTR-9 is not mandatory for us based on our turnover, we opted to file it
voluntarily to ensure transparency, maintain compliance with GST regulations, and provide a
clear record of our annual tax details.
Therefore, the specified late fees of Rs. 8,000/- (CGST/SGST – Rs.4,000/each) it is not liable
for us to be paid. Hence, we request you to drop further proceedings in this regard.
ROCK & ROLL BROS
36/2, BHARATHIAR STREET, MANIYAKARAMPALAYAM ROAD,
GANAPATHY, COIMBATORE - 641006, TAMIL NADU (State Code: 33)
GSTIN: 33AAWFR0920L1ZW
Net Payable Summary
S. Particulars IGST CGST SGST Total
No
1 Reconciliation of E-waybill with GSTR1 - - - -
2 Excess claim of ITC in GSTR-3B w.r.t GSTR-9 - - - -
3 ITC to be reversed on non-business transactions & Exempt - - - -
Supplies
4 Interest in Invoice Value increased through amendments - 11 11 22
5 GSTR-1 Late Fees - 150 150 300
6 GSTR-9/9C Late Fees - - - -
7 Net Payable - 161 161 322
Considering the above clarifications, we request you to drop further proceeding for all the above
mentioned defects except the defect of non-reconciliation of E-waybill turnover with GSTR1
turnover. Further, we request you to grant the additional time of 15 working days to assist in
providing a detailed reconciliation of the E-waybill(s) with GSTR-1 invoices.
We are glad to provide additional documents / clarification in this regard.
Thanking you.
Yours faithfully,
For ROCK & ROLL BROS
PARTNER
Encl: As above.
