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All Case Studies
Retail / Consumer Goods GST

Retail Chain — Resolving a GST Input Tax Credit Mismatch Demand

A pan-India retailer was hit with a DRC-01 demand over an ITC mismatch caused by defaulting vendors. We built the reconciliation and the legal defence that cut the demand by 80%.

Client Type
Retail / Consumer Goods | Private Limited
Annual Turnover
₹40 Crore+
Location
Pan-India (HQ Mumbai)
Engagement
GST Adjudication & Defence
The Challenge

A demand built on someone else's omissions.

The retailer was served a GST DRC-01 notice demanding a large sum in unpaid taxes, interest, and penalties. The demand arose from a significant Input Tax Credit (ITC) mismatch between the client's GSTR-3B filings and the GSTR-2A data — the direct result of poor vendor management. Numerous small-scale suppliers had simply failed to upload their invoices, leaving the client legally exposed for tax it had already paid to those vendors. The job was to reconcile commercial reality with GST law, and to defend credit that was genuine.

Our Approach

How we turned the demand around.

01

Automated Forensics

We ran a line-by-line automated reconciliation of the purchase register against GSTR-2A/2B to isolate every non-compliant vendor.

02

Vendor Enforcement

We identified the defaulters and coordinated directly with them to get missing returns filed — effectively forcing the data to populate the portal.

03

Legal Defence

We drafted a comprehensive reply invoking Section 16(2) of the CGST Act, with a bulletproof evidence trail: proof of payment and proof of receipt of goods establishing the credit's legitimacy.

04

Adjudication Representation

We represented the client before the Adjudicating Authority, arguing that a taxpayer should not be penalised for the clerical omissions of third parties when the underlying transaction is genuine.

Expertise Delivered

The capabilities we brought to bear.

GSTR-2A / 2B Reconciliation

Automated matching of the purchase register to portal data to isolate every gap.

Section 16(2) Defence

Credit legitimacy established on documentary merits, not portal artefacts.

Vendor Compliance Systems

A dashboard that releases payment only once a vendor's filings are confirmed.

Adjudication Representation

Direct appearance and argument before the GST authority.

Key Outcomes

The results we delivered.

80% reduction in the total demand
Principal tax reconciled and associated penalties waived entirely on the merits
A Vendor Compliance Dashboard implemented to prevent any recurrence
ITC protected and treated as the cash asset it is

GST ITC is a cash asset, and proactive vendor management is the only way to protect it from departmental scrutiny.

— NDS Advisors

Facing a GST notice or ITC mismatch?