Second leg of communication of data (CIN with embedded CPIN) starts from Authorized banks / RBI to GSTN (T=0):
106. This communication is not meant to be the basis for accounting, but act as an enabler to reduce errors in the overall process and to facilitate fleet-footed monitoring by the Tax Authorities. The IT system of the authorized banks should have the following validations to reduce possibility of discrepancies in this leg:-
a) In any reporting of successful transactions by the banks to GSTN, CPIN field is never a blank;
b) The response sent back to GSTN is always against a CPIN received from GSTN;
c) Sum total of all credits to Tax accounts for a particular CPIN adds up to the challan amount.
d) CIN reported by the authorized banks/RBI should always have a CPIN embedded in it.
107. In spite of the above mentioned validations, if a discrepancy is found in a bank’s response, the discrepancy will get noticed in the real time validation of the response by the GSTN. The response sent by e-FPB of authorized bank (in Mode I & II) / RBI (in Mode III) should be validated with the data sent earlier by GSTN to Authorized bank / RBI. Key elements are CPIN, GSTIN, CIN & Challan amount in case of authorized banks and CPIN, GSTIN, CIN, NEFT/RTGS UTR and Challan amount in case of RBI. This validation between CPIN available with GSTN and CIN received from e-FPB of authorized banks / RBI should be done on real time basis and the discrepancies, if found should be communicated to the concerned banks immediately by GSTN’s IT system so as to enable time to the banks for correction, if possible, before communicating the receipts to RBI on T+1 basis.
108. The validation by GSTN may throw up following discrepancies in the transaction being reported (with CIN added by the bank) by e-FPB of authorized bank / RBI:
a) without CPIN;
b) with incorrect CPIN;
c) with challan amount mismatch.
109. In all these cases, the resolution at e-FPB may require manual intervention. The bank may resend the data to GSTN after correction. If the bank is unable to resolve by T+1 reporting time to RBI, the bank should include the transaction in the luggage file with whatever CPIN data it may have for that transaction. It will be type (c) error in the third leg.
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