Annual GST compliance requires businesses to establish a clear audit trail between reverse charge taxes discharged and credits availed. In Form GSTR-9, Table 4G consolidates total inward supplies liable to reverse charge under Section 9(3) and Section 9(4) of the CGST Act. Conversely, Table 6 breaks down input tax credit availed during the financial year, separating RCM credit received from unregistered persons in Table 6C from registered suppliers in Table 6D.
A mismatch between tax paid under Table 4G and credit availed under Table 6C and Table 6D is one of the most common triggers for notice in FORM GST ASMT-10 under Rule 99(1) of the CGST Rules. While taxpayers expect both sides to balance, legitimate statutory differences routinely occur.
Understanding the statutory architecture of Table 4G, 6C, and 6D
To reconcile these figures accurately, accountants must understand how the GST common portal populates and cross-references each table from monthly GSTR-3B returns:
| GSTR-9 Table | Source Table in Form GSTR-3B | Statutory Scope | Editable in GSTR-9? |
|---|---|---|---|
| Table 4G | Table 3.1(d) (Inward supplies liable to reverse charge) | Total tax payable by recipient under Section 9(3) and 9(4) | Yes (taxpayer can modify actuals) |
| Table 6A | Table 4(A) (Total ITC availed) | Consolidated ITC availed across all categories in GSTR-3B | No (auto-populated and non-editable) |
| Table 6C | Part of Table 4(A)(3) (Inward supplies liable to reverse charge) | ITC availed on RCM supplies from unregistered persons | Yes (manual bifurcation required) |
| Table 6D | Part of Table 4(A)(3) (Inward supplies liable to reverse charge) | ITC availed on RCM supplies from registered persons | Yes (manual bifurcation required) |
Under GSTN Form GSTR-9 specifications, Table 6A is auto-filled directly from the monthly GSTR-3B filings and cannot be changed. The taxpayer must then bifurcate the total credit across Table 6B, Table 6C, Table 6D, and Table 6E. For a comprehensive review of this allocation, refer to our detailed guide on GSTR-9 Table 6 ITC availed bifurcation.
Five reasons Table 4G does not equal Table 6C plus Table 6D
Auditors frequently encounter variance between RCM tax paid in Table 4G and RCM credit taken in Table 6C and Table 6D. The most frequent operational and legal reasons include:
- Blocked credits under Section 17(5): RCM liability must be paid in full on all notified inward supplies, even if the underlying service is blocked from input tax credit. For example, reverse charge paid on security services or rent-a-cab for non-eligible business purposes must be reported in Table 4G as tax payable, but excluded from Table 6C and Table 6D.
- Timing differences across financial years: Tax liability under RCM might be discharged through cash in GSTR-3B of March (reflected in Table 4G), but the corresponding credit is availed in April or May of the subsequent financial year. Such subsequent-year credits are reported in Table 13 of Form GSTR-9 rather than Table 6C or Table 6D.
- Exempt supplies or non-business usage: Where reverse charge services relate to exempt outward supplies or personal consumption, the tax must still be paid in cash under Table 4G, while the ITC must either not be claimed or reversed under Rule 42.
- Unregistered procurement documentation: Under Rule 47A of the CGST Rules read with Section 31(3)(f), the recipient must issue a self-invoice for supplies received from unregistered persons. Failure to generate prompt self-invoices often delays credit availing while liability is paid on estimated figures.
- Omission of legal service RCM: Businesses procuring representation from advocates often fail to identify fee payments in general ledger ledgers. To ensure full compliance with reverse charge notifications, verify your legal expenses against our checklist for RCM on legal services by advocate and ITC claim.
Common mistake: Never use input tax credit from the Electronic Credit Ledger to pay reverse charge liability. Under Section 49(4) of the CGST Act, reverse charge tax is an output liability payable by the recipient and must be discharged exclusively through cash ledger debits.
Worked reconciliation: M/s Apex Logistics Private Limited
Consider M/s Apex Logistics Private Limited, a registered entity that received various RCM services during the financial year. The company paid reverse charge tax in cash through monthly GSTR-3B filings and maintained detailed procurement books.
| Nature of Inward Supply | Supplier Status | Taxable Value | GST Rate | RCM Tax Payable (Table 4G) | ITC Eligibility | ITC Availed (Table 6C / 6D) |
|---|---|---|---|---|---|---|
| Goods Transport Agency (GTA) | Unregistered | ₹10,00,000 | 5% | ₹50,000 | Eligible (Business freight) | ₹50,000 (Table 6C) |
| Legal services by advocate | Unregistered Individual | ₹2,00,000 | 18% | ₹36,000 | Eligible (Commercial litigation) | ₹36,000 (Table 6C) |
| Director sitting fees | Registered Director | ₹1,00,000 | 18% | ₹18,000 | Eligible (Company governance) | ₹18,000 (Table 6D) |
| Security personnel services | Unregistered firm | ₹1,50,000 | 18% | ₹27,000 | Blocked under Section 17(5)(g) | ₹0 (Ineligible) |
| Total | N/A | ₹14,50,000 | N/A | ₹1,31,000 | N/A | ₹1,04,000 |
In this example, the reconciliation statement reflects:
- Table 4G tax payable: ₹50,000 + ₹36,000 + ₹18,000 + ₹27,000 = ₹1,31,000.
- Table 6C ITC availed (unregistered): ₹50,000 (GTA) + ₹36,000 (Legal) = ₹86,000.
- Table 6D ITC availed (registered): ₹18,000 (Director remuneration).
- Total ITC availed under RCM: ₹86,000 + ₹18,000 = ₹1,04,000.
- Variance: ₹1,31,000 − ₹1,04,000 = ₹27,000, representing security services where credit is blocked under Section 17(5).
Because the ₹27,000 difference is justified by statutory credit restrictions, the company documents this reconciliation schedule in its working papers to answer any future ASMT-10 scrutiny notice.
Step-by-step audit workflow before filing GSTR-9
Follow this systematic procedure to reconcile RCM balances before submitting Form GSTR-9 on the GST common portal:
- Extract expense ledgers: Filter all freight, legal, director sitting fee, security, and sponsorship expense heads from your accounting software.
- Verify Electronic Cash Ledger debits: Confirm that tax was actually discharged in cash via monthly Form GSTR-3B Table 6.1 payments.
- Check Section 31(3)(f) self-invoices: Ensure payment vouchers and self-invoices exist for all unregistered RCM transactions. Note that under CBIC clarification, self-invoices generated under Section 31(3)(f) do not require an IRN from the e-invoicing portal.
- Isolate blocked credits: Identify any RCM tax paid on items falling within the negative list of Section 17(5) and confirm that these credits were not included in Table 4(A)(3) of Form GSTR-3B.
- Discharge unpaid liabilities: If the audit reveals omitted RCM transactions, report the unpaid tax in GSTR-9 and discharge the liability in cash using Form GST DRC-03.
How to discharge differential RCM liability
If you identify undeclared RCM liability during your annual return preparation, you cannot pay it directly inside Form GSTR-9. Under CBIC GSTR-9 Instructions, any additional tax liability must be discharged through Form GST DRC-03.
Navigate to Services → User Services → My Applications → Application for intimation of voluntary payment (DRC-03). Select Annual Return as the cause of payment, enter the tax liability under the appropriate tax heads (CGST, SGST, or IGST), and discharge the liability using the Electronic Cash Ledger. Calculate and include interest payable under Section 50 at 18% per annum from the original due date of the return.
Frequently asked questions
Why do Table 4G and Table 6C differ in Form GSTR-9?
Table 4G records inward supplies on which reverse charge liability is payable, whereas Table 6C and Table 6D record input tax credit actually availed. Differences arise when tax is paid on ineligible expenses under Section 17(5), when tax is paid in cash in one month but ITC is claimed in a subsequent period, or when reverse charge liability on unregistered procurement is under-reported.
Can RCM tax liability declared in GSTR-9 be settled using input tax credit?
No. Under Section 49(4) of the CGST Act, reverse charge tax is an output tax liability payable by the recipient and must be discharged exclusively through the Electronic Cash Ledger. Input tax credit cannot be used to pay reverse charge liability.
How is unpaid RCM liability identified during annual reconciliation discharged?
Unpaid reverse charge liability discovered during annual return preparation must be paid through Form GST DRC-03 in cash by selecting Annual Return from the dropdown list, along with applicable interest under Section 50.
Reconcile your inward supplies with complete data privacy
Matching registered vendor RCM invoices against your books requires granular reconciliation against your monthly GSTR-2B statements. Your GSTR-2B and purchase register files are read in your browser and never uploaded to any server.
Last checked: 27 October 2026. Sources: CBIC Tax Repository - CGST Act Section 9, GSTN Form GSTR-9 User Manual and FAQs.