GSTAgent›Workflows›Self-Invoice Compliance Check

RCM Compliance⏱ 5 min

📄

Self-Invoice Compliance Check

Verify self-invoices u/s 31(3)(f) are issued for every RCM entry. Catch missing documents before audit.

Every RCM transaction requires the recipient to issue a self-invoice under Section 31(3)(f) of the CGST Act. This document is the legal basis for both the RCM liability and the subsequent ITC claim. Missing self-invoices attract ₹50,000 penalty per offence — separate from the RCM tax. GSTAgent cross-checks RCM entries against self-invoice records.

Sec 31(3)(f)Self-invoiceRCMDocumentation

Check Self-Invoice Compliance →

The Problem

Why this needs to be automated

📋

Self-invoices are rarely tracked systematically

Most CA firms track RCM payment in GSTR-3B but don't separately verify that a self-invoice was issued for each entry in the same period. The penalty for missing self-invoices is independent of paying the RCM tax.

⚠

₹50,000 penalty per missing self-invoice

Section 122(1)(ai) imposes a minimum penalty of ₹50,000 per offence for failure to issue a tax invoice including self-invoice. For a firm with 12 months of RCM entries, exposure can be ₹6,00,000+.

📅

Self-invoice must be in same period as RCM

The self-invoice must be issued in the same month as the RCM transaction. Backdated self-invoices do not protect against penalty for the original period.

Regulatory Context

The law that makes this matter

Sec 31(3)(f)

Self-invoice — mandatory

Where a registered person receives supply from an unregistered person or receives a notified RCM supply, they must issue a self-invoice.

Sec 31(3)(g)

Payment voucher

For RCM supplies where invoice is not available, a payment voucher must be issued at the time of making payment to the supplier.

Sec 122(1)(ai)

Penalty for missing invoice

Penalty of ₹50,000 (₹25,000 CGST + ₹25,000 SGST) or the amount of tax involved, whichever is higher, for failure to issue a tax invoice.

How It Works

4 steps. Mostly automated.

Identify all RCM entries

From the RCM Register — all confirmed RCM entries with date, supplier, category, and tax amount.

Match against self-invoice records

Check Tally for corresponding self-invoice vouchers in the same period for each RCM entry.

Flag missing self-invoices

Entries with no matching self-invoice in the same period are flagged. Penalty exposure computed per entry.

Compliance checklist generated

Complete checklist: RCM entries, self-invoice status, payment voucher status, GSTR-3B Table 3.1(d) payment confirmed.

Sample Output

What you actually see

Sample data — Metro Print Works Pvt. Ltd · FY 2026-27

RCM entries checked

Self-invoices confirmed

Missing self-invoices

Payment vouchers confirmed

Cash payment via 3B confirmed

ITC reclaimed in same period

₹1,38,600

Sample data for illustration only. Actual results depend on your client's Tally data. Not professional tax advice.

Edge Cases

How GSTAgent handles the tricky ones

Scenario	GSTAgent Output
Self-invoice issued next month for prior month RCM	Flagged — self-invoice must be in same period as supply
Single self-invoice covering multiple RCM transactions	Accepted if same supplier and same period — flagged for CA verification
RCM paid in cash but self-invoice missing	RCM tax obligation met — but penalty risk for missing document remains

₹50,000

Penalty per missing self-invoice

5 min

Complete compliance check

Same period

Self-invoice must match RCM month

3 docs

Self-invoice + payment voucher + 3B entry

FAQ

Common questions

What information must be in a self-invoice?

Name and address of supplier, GSTIN of recipient, consecutive serial number, date, description of supply, value of supply, applicable tax rate and amount, and place of supply.

Can the self-invoice be in Tally?

Yes — Tally supports self-invoice creation for RCM. The voucher should be of type Purchase and marked as self-invoice under GST details.

Is a payment voucher the same as a self-invoice?

No — they serve different purposes. A payment voucher u/s 31(3)(g) is issued at time of payment when no invoice exists. A self-invoice u/s 31(3)(f) is issued in lieu of the supplier's invoice.

What if the supplier is registered but the supply is under Sec 9(3)?

Some Sec 9(3) categories (like GTA opting out of 12% GST) require RCM even if the supplier is registered. Self-invoice is required in those cases too.

Ready to run this workflow?

A GSTAgent subscription code is required. CA firm plans from ₹1,400/month for 10 clients.

Check Self-Invoice Compliance →View pricing ← All workflows