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How-To · 12 min read

Section 143 Deemed Supply — 1-Year Job-Work Return Rule for Textile

Section 143(3) of the CGST Act gives an Indian textile principal exactly one year to receive processed inputs back from a job-worker (three years for capital goods). Miss the deadline by a single day and the original outward movement is deemed a taxable supply from the date of dispatch — GST liability retro-recognised, Section 50 interest running from Day 0. The reconciliation between dispatch challan, pending-balance ledger, and D-30 escalation is the single most audit-critical control in a Tiruppur, Coimbatore, or Surat job-work chain.

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Published 6 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Knowledge Card
Problem

Indian textile principals under the Section 143 CGST job-work regime send yarn, greige fabric, semi-processed cloth, and specialised inputs to external knitters, dyers, weavers, and finishers under Rule 55 delivery challans, retaining ownership throughout. Section 143(3) imposes a strict 1-year clock (3 years for capital goods) from the dispatch date. If the goods are not received back within the window, the original outward movement is retro-treated as a taxable supply from Day 0 — GST liability crystallises at the taxable value of the dispatch, Section 50 interest runs at 18% per annum from the dispatch date, and self-assessment must be reported in the GSTR-3B for the month the anniversary falls. In multi-hop textile chains passing through spinning, knitting, dyeing, weaving, and finishing units, a single-owner view of the pending balance across all hops is the difference between clean ITC-04 filing and a Section 73/74 notice.

How It's Resolved

Build a pending-balance register keyed by delivery challan number. Each row captures: challan date, job-worker GSTIN, HSN, description, quantity dispatched, taxable value, process turnaround expected, and the 1-year statutory deadline. Inward return challans consume the pending balance line-by-line, matched by challan reference and reconciled at quantity level with a defined shrinkage allowance per process. A daily job runs the residual-balance report and flags every open challan at D-90 (early warning), D-60 (escalation to job-worker), and D-30 (senior-management alert). The register locks at each ITC-04 cut-off and generates the return. Any line crossing D+0 (past the anniversary) triggers a GSTR-3B self-assessment worksheet computing the deemed-supply tax and Section 50 interest, and disclosure in the next GSTR-1.

Configuration

Delivery challan master with challan number, date, job-worker GSTIN, HSN, description, quantity, taxable value, expected turnaround, and 1-year deadline (3-year for capital goods flag); process turnaround matrix per operation (spinning, knitting, dyeing, weaving, printing, finishing) with shrinkage allowance percentage; job-worker master with GSTIN, PAN, ITC-04 reporting flag, and Section 393(1) Sl. 4 payment code (1023 for material-supplied job-work, 1024 for non-supplied); escalation thresholds (D-90, D-60, D-30) with distribution list per threshold; GSTR-3B self-assessment worksheet template for deemed-supply lines; GSTR-1 disclosure template for deemed outward supplies; ITC-04 cadence (half-yearly for turnover up to ₹5 crore, quarterly above).

Output

A live pending-balance register showing every open job-work challan with days-since-dispatch and days-to-anniversary. A residual-balance dashboard by job-worker highlighting D-90, D-60, D-30, and past-anniversary lines. A GSTR-3B self-assessment worksheet for any past-anniversary lines with tax and Section 50 interest computed. A GSTR-1 outward-supply disclosure entry. An ITC-04 return generated from the register at each cut-off, tied mathematically to opening balance plus inputs sent minus inputs received equals closing balance. A monthly leakage report for finance and audit — clean job-work chains sustain zero deemed-supply crystallisations year on year.

A Coimbatore spinning-integrated mill closes its April 2026 review with 214 open job-work delivery challans across 47 external knitters, dyers, and finishing units — dispatched value approximately ₹42 crore of yarn, greige fabric, and semi-processed cloth. The reconciliation register shows 189 challans within normal turnaround, 18 in the D-60 to D-30 window with active escalation to the job-worker, and 7 past the D-30 threshold with fewer than 30 days remaining before the Section 143 1-year statutory deadline expires. Of the 7 past-D-30 lines, 4 relate to a single Tiruppur circular-knit specialist whose machinery breakdown in October 2025 pushed the entire spring collection into a shipping backlog; the specialist has confirmed a return schedule within 12 days, but the mill’s controller is preparing the GSTR-3B self-assessment worksheet for the anniversary month in case even one line slips. Total deemed-supply exposure across the 7 lines if all crystallise: approximately ₹1.1 crore of tax at the 5%-to-12% textile GST slabs plus roughly ₹19 lakh of Section 50 interest — call it 3 percent of the open dispatched value at risk from a single week of delay. This is Section 143 deemed supply textile job work 1 year at production scale, and the reconciliation discipline that resolves it is the single most audit-critical control in an Indian textile principal’s finance stack.

Quick reference

AspectDetail
Governing provisionSection 143(3), Central Goods and Services Tax Act 2017
Clock for inputs1 year from dispatch date on delivery challan
Clock for capital goods3 years from dispatch date on delivery challan
Deemed-supply date if breachedThe original dispatch date (retroactive to Day 0)
Interest under Section 5018% per annum from the original dispatch date
Reporting returnGSTR-3B (self-assessment) plus GSTR-1 (outward disclosure) in the anniversary month
Movement documentRule 55 delivery challan in triplicate (Form GST INS-01)
Periodic returnForm GST ITC-04 — half-yearly if turnover ≤ ₹5 crore, quarterly if > ₹5 crore
Job-work TDS codeSection 393(1) Sl. 4 code 1023 (material supplied by customer)
E-invoicing threshold₹5 crore aggregate turnover from 1 August 2023

What Section 143 deemed supply actually is

Section 143 of the CGST Act creates a structured tax-neutral corridor for job-work — the movement of inputs and capital goods from a registered principal to a job-worker for further processing, without the ownership of the goods passing to the job-worker. Under the corridor, the principal continues to hold title, the job-worker performs the process against a service charge, and the goods eventually return to the principal (or move directly to the customer under the extended-place-of-business provisions) for onward sale. The corridor exists because taxing every outward movement to a job-worker and every inward return would create a hall-of-mirrors GST liability with no economic value creation.

The corridor comes with a statutory time-fence. Section 143(3) provides that if the inputs sent to the job-worker are not received back within one year of being sent out — three years for capital goods — the outward movement is deemed to have been a taxable supply from the day it was sent out. The moment the anniversary passes without receipt, the principal is retro-liable for GST on the value of the dispatched inputs as though a normal outward sale had happened on Day 0, and Section 50 interest at 18% per annum runs on that liability from the original dispatch date. There is no cure period, no penalty-only escape, no discretion. The clock expires, the tax crystallises, and the disclosure must land in the next GSTR-3B and GSTR-1.

In the textile chain, the 1-year clock is uniquely fragile because the operational reality involves multiple external processes, seasonal peaks, quality-rejection loops, and multi-hop movement. A vertically integrated mill in Coimbatore may spin yarn in-house, dispatch it to a Tiruppur knitter for circular-knit fabric, direct the knitter to send the greige fabric to a Erode dyeing house, and receive the dyed fabric back for cut-and-sew at its own garment unit. Under Section 143, the entire chain is legally the principal’s responsibility, and the 1-year clock from the principal’s Day-0 dispatch of yarn runs continuously through every hop. If the final dyed fabric returns 380 days after the yarn left the mill, the entire yarn dispatch is a deemed supply — the fact that the delay happened at the dyer, not the knitter, does not restart the clock.

Why the 1-year clock is uniquely fragile in Indian textile chains

Three operational realities make the Section 143 clock the single most audit-critical control in a textile finance stack. First, textile job-work chains are multi-hop by nature — a spinning-integrated principal in Coimbatore does not perform knitting, dyeing, printing, or finishing in-house because scale economics push each step to a specialist. Under Section 143, the principal can authorise direct hop-to-hop movement between job-workers so the goods do not return to the mill between hops — this is operationally efficient but concentrates the 1-year risk on a single Day-0 clock. Second, the textile export calendar is dominated by spring-summer and autumn-winter windows with 6-to-9-month lead times; a spring collection order in July can pull yarn out of the mill in July for finished-fabric receipt in March or April next year, leaving barely any buffer against the 1-year statutory deadline. Third, quality-rejection loops in the dyeing and finishing stages routinely add 30 to 90 days per rejection cycle, and rejection is not visible to the principal until the fabric arrives back and inspection fails.

Layer on top the specific fragility of certain cluster geographies. The Tiruppur circular-knit ecosystem runs on aged machinery in many mid-tier units, and a machinery breakdown at a single knitter can back up 30 to 60 days of the principal’s fabric pipeline. The Surat processing cluster faces monsoon-linked shipping disruption between June and September. The Panipat home-furnishing cluster faces power-cut cycles that push finishing timelines. The Bhilwara suiting cluster faces yarn-carrier constraints during peak festival transport windows. Each geography adds structural risk to the Day-0 dispatch that the principal has no direct control over — only the pending-balance register catches the drift before the clock expires.

The regulatory overlay — Section 143, Rule 45, Rule 55, and Section 50

The four provisions that govern the reconciliation are Section 143 of the CGST Act (the deemed-supply framework), Rule 45 of the CGST Rules (the conditions and restrictions on inputs sent to job-worker), Rule 55 of the CGST Rules (the delivery-challan procedure), and Section 50 of the CGST Act (the interest computation on delayed tax). Together they define the compliance surface.

Section 143(1) permits the principal to send inputs or capital goods to a job-worker without payment of tax under intimation to the tax authorities. Section 143(1)(a) additionally permits the principal to send goods directly from a supplier to the job-worker without the goods being received at the principal’s premises first — useful in scenarios where the mill orders yarn from an external supplier and directs delivery straight to the knitter. Section 143(2) permits the principal to send goods from one job-worker to another job-worker for a further process without the goods returning to the principal in between. Section 143(3) is the deemed-supply provision that fires if the inputs are not received back within 1 year of being sent out. Section 143(4) is the equivalent 3-year rule for capital goods. Section 143(5) permits the principal to supply the goods directly from the job-worker’s premises to the customer, provided the job-worker is registered under GST or the principal has declared the job-worker’s premises as an additional place of business.

Rule 45 lays down the procedural conditions. Rule 45(1) requires that inputs, semi-finished goods, or capital goods be sent under the cover of a delivery challan issued by the principal. Rule 45(2) permits the movement of goods from one job-worker to another job-worker also under the cover of a delivery challan. Rule 45(3) requires the principal to furnish Form GST ITC-04 for the periodic reporting of the movement.

Rule 55 specifies the contents of the delivery challan. The challan must carry: challan number and date; principal’s name, address, and GSTIN; job-worker’s name, address, and GSTIN (or unregistered supplier declaration if applicable); HSN code of the goods; description; quantity; taxable value; place of supply; and signature. The challan must be issued in triplicate — one copy accompanies the goods (the transporter’s copy for e-way bill and inspection), one copy is retained by the job-worker, and one copy is retained by the principal. The e-way bill under Rule 138 must be generated on the challan for inter-state movement or intra-state movement above the state’s threshold.

Section 50 computes the interest on delayed tax at 18% per annum for the period the tax remains unpaid. For a Section 143 deemed-supply liability, the “period” runs from the original dispatch date to the date the tax is actually paid. In a 1-year-plus-30-days scenario, the interest works out to approximately 19.5% of the tax amount — a hard number, not a discretionary penalty.

A worked example — Coimbatore mill dispatches yarn to Tiruppur circular-knit specialist

A vertically integrated spinning mill in Coimbatore dispatches 2,500 kg of specialty combed cotton yarn to an external circular-knit specialist in Tiruppur for a spring-summer collection. The dispatch is documented on Rule 55 delivery challan dated 15 March 2026, GSTIN of both parties recorded, HSN 5205 (single-yarn cotton, uncombed and combed), taxable value ₹18 lakh, movement under Section 143 without payment of tax. The knitter’s expected turnaround is 90 days to deliver the knit fabric. The mill’s reconciliation register records the 1-year statutory deadline as 14 March 2027.

Illustrative — figures are representative of a mid-scale Tiruppur specialty knit dispatch; cross-verify against your own delivery-challan file and job-work register before action.

Between April and October 2026, the reconciliation register runs its daily residual-balance job. On 14 September 2026 (D-180 from anniversary), an alert fires because the challan is still open — the knitter reports a machinery breakdown on the 34-inch circular-knit line and estimates a 45-day recovery. On 14 December 2026 (D-90 from anniversary), the mill escalates the recovery-schedule request. On 14 January 2027 (D-60 from anniversary), formal escalation is sent to the knitter’s finance and operations heads with a copy to the mill’s merchandising team. On 12 February 2027 (D-30 from anniversary), a senior-management alert fires with a contingency-planning trigger. On 5 March 2027 (9 days from anniversary), the knitter confirms a return schedule for 22 March 2027 — 8 days past the statutory deadline.

The mill’s controller draws up the GSTR-3B self-assessment worksheet.

Section 143 deemed-supply computationAmount
Original dispatch value (taxable value on challan)₹18,00,000
Applicable GST rate (HSN 5205, cotton yarn)12%
Deemed-supply tax (CGST 6% + SGST 6% intra-state)₹2,16,000
Period from original dispatch (15 March 2026) to anniversary (14 March 2027)364 days
Section 50 interest at 18% per annum for 364 days₹38,772
Total exposure at anniversary₹2,54,772
Exposure as percent of original dispatched value14.15%

The controller has three actionable choices. First, absorb the deemed-supply liability — self-assess and pay ₹2,54,772 in the March 2027 GSTR-3B, disclose the deemed outward supply in the March 2027 GSTR-1 at the taxable value of ₹18 lakh, and when the fabric arrives on 22 March 2027, book the inward movement as a fresh transaction rather than as a Section 143 return. The GST already paid remains as ITC recoverable against future outward supplies. Second, negotiate a recall — issue a formal recall notice to the knitter before the 14 March anniversary and take physical delivery of whatever finished or semi-finished stock is available at the knitter’s premises before the deadline, restarting the clock for any residual work that must go back. This is operationally hard on specialty knit but salvages a large fraction of the pipeline. Third, treat the delayed movement as a supply of services by the job-worker where the principal takes the semi-finished output at Day 364 and completes the process in-house — legally cleaner because it converts the outward movement to a supply of services with GST liability computed on the service charge, not on the original dispatch value.

The mill’s finance leadership adopts Option 1 for the affected line — the deemed-supply liability is booked cleanly in the March 2027 self-assessment, and the merchandising team is instructed to reduce the aged-machinery exposure by moving the next collection’s circular-knit spec to a secondary supplier with newer equipment. The controller adds a scheme condition to the sourcing register: any specialty knit dispatch to a job-worker with mean-time-to-repair above a threshold requires a written return-schedule confirmation before Day 0 dispatch.

Common reconciliation breakages

  • Delivery challan file drift — challans issued at the shop-floor level in mid-tier mills, entered into the ERP with 3-to-7-day lag, and the 1-year clock computed off the ERP-entry date rather than the actual dispatch date. When the anniversary arrives, the register shows margin that does not exist. Cure: the challan number must be issued from the ERP at dispatch, not retro-entered later.
  • Multi-hop movement without single-owner tracking — principal authorises knitter to send greige fabric direct to dyer, dyer to send dyed fabric direct to finisher, and the principal’s register only shows the yarn dispatched and the finished fabric received. Intermediate movement is invisible, and if a hop stalls, the clock has been running the whole time. Cure: capture every hop’s delivery challan in the principal’s register even when the goods do not physically return to the principal.
  • Quantity reconciliation with process shrinkage — yarn dispatched at 2,500 kg comes back as 2,340 kg of knit fabric after shrinkage in knitting; the register consumes 2,340 kg and shows 160 kg as still open indefinitely. Cure: define a shrinkage allowance percentage per process (typical spans: knitting 3-6%, dyeing 4-8%, printing 2-5%, finishing 2-4%) and close the residual within the tolerance.
  • Return of capital goods clock treated as 1 year — job-work dispatches of embroidery machines, cutting dies, or specialty tooling under Section 143 face the 3-year clock, not the 1-year clock. Common error: system flags a capital-goods dispatch as approaching D-30 at Day 335 when it actually has 2 years remaining, causing false-positive alerts that erode confidence in the register.
  • ITC-04 reconciliation not tied to the register — return prepared from a separate spreadsheet, closing balance does not tie to the principal’s register, and the auditor’s mismatch notice arrives the next quarter. Cure: generate ITC-04 as an output of the register, not as a parallel workstream.

How a reconciliation platform handles this

An enterprise reconciliation platform ingests the delivery challan file from the ERP at dispatch, matches every inward return challan by challan reference at line-item level, applies the shrinkage allowance from the process matrix, runs a daily residual-balance job that flags D-90, D-60, and D-30 lines to finance and merchandising, and generates the ITC-04 return automatically at each cut-off. For any past-anniversary line, the platform produces a GSTR-3B self-assessment worksheet with the tax and Section 50 interest computed to the day. Textile principals working through this discipline typically move from a manually maintained register with 45-to-60-day drift to a live register with zero drift, and the year-end audit exposure on Section 143 deemed supply drops from a floating risk to a controlled disclosure. For principals also managing multi-hop job-work reconciliation across knitting, dyeing, and finishing units, and ITC-04 quarterly return preparation, the same register feeds both surfaces without a parallel data pipeline.

The textile Section 143 clock has close cousins in other industries. FMCG contract manufacturing under Section 193/194C for contract manufacturers runs the same delivery-challan and pending-balance discipline for finished goods coming back from third-party co-manufacturers. Auto components under Section 43B(h) MSME 45-day payment reconciliation faces a different statutory clock but the same escalation-threshold pattern. GST-side reconciliation across IMS automation helps textile principals close the loop on ITC accepted, rejected, and pending on the input side. Related textile-cluster articles: Rule 55 delivery challan for textile job-work movement walks the document procedure; ITC-04 quarterly return textile job-work reconciliation covers the periodic return; free-issue yarn and fabric job-work reconciliation covers the free-issue accounting angle. The commercial pillar is Textile reconciliation software India.

The five FAQs below address the operational questions Indian textile controllers ask most often when implementing structured Section 143 pending-balance reconciliation.

Primary reference: CBIC GST portal — for Section 143 CGST job-work provisions, Rule 45 and Rule 55 delivery-challan procedure, Rule 138 e-way bill for job-work movement, and Section 50 interest computation on delayed GST liability.
Primary sources cited
Last reviewed against sources on 6 July 2026
  • Section 143, Central Goods and Services Tax Act 2017 — Job-work procedure. A registered principal may send inputs or capital goods to a job-worker without payment of tax under intimation. Inputs must be received back within one year and capital goods within three years from the date of being sent out. If the inputs are not received back within the stipulated period, it shall be deemed that such inputs had been supplied by the principal to the job-worker on the day when the said inputs were sent out.
  • Rule 45 and Rule 55, Central Goods and Services Tax Rules 2017 — Conditions and restrictions in respect of inputs and capital goods sent to the job-worker. Rule 45 requires the principal to send inputs or capital goods under the cover of a delivery challan. Rule 55 specifies the contents of the delivery challan — challan number and date, sender and recipient details, HSN, description, quantity, taxable value, place of supply, and signature. The challan must be issued in triplicate.
  • Section 50, Central Goods and Services Tax Act 2017 — Interest on delayed payment of tax. Every person who is liable to pay tax under this Act, but fails to pay the tax or any part thereof to the Government within the period prescribed, shall pay interest at the rate of eighteen per cent per annum for the period for which the tax or any part thereof remains unpaid.
  • Form GST ITC-04 and Rule 45(3), Central Goods and Services Tax Rules 2017 — Return of inputs and capital goods sent to job-worker. To be furnished half-yearly (by 25 October for April-September and 25 April for October-March) if aggregate turnover in the preceding financial year is up to ₹5 crore, and quarterly if aggregate turnover exceeds ₹5 crore. Reports opening balance, inputs sent, inputs received back, and closing balance.
  • Section 393(1) Sl. 4 payment code 1023, Income-tax Act 2025 — TDS on payments to contractors — job-work where material is supplied by the customer. Successor to legacy Section 194C for material-supplied job-work in the textile chain. 1% for individual/HUF payees, 2% for other payees. The TDS obligation is separate from the Section 143 CGST deemed-supply clock but reconciles at the same challan level.

Frequently Asked Questions

What triggers Section 143 deemed supply in a textile job-work chain?
Section 143(3) of the CGST Act triggers deemed supply when inputs sent by a registered principal to a job-worker under delivery challan are not received back within one year from the date the inputs were sent out (three years for capital goods). The trigger is automatic and unforgiving — as of the day after the one-year anniversary of the dispatch date, the original outward movement from the principal to the job-worker is treated as a taxable supply from Day 0, not from the anniversary date. The principal becomes liable to pay GST on the taxable value of the inputs as though a normal outward supply had been made on the original dispatch date. Section 50 interest at 18% per annum runs from the original dispatch date on the tax so payable. The principal can still recover the goods later, but the deemed-supply consequences do not reverse — once the clock expires, the tax and interest liability crystallises. In textile chains the most common triggers are job-worker machinery breakdown, shipping delays on knitted or processed fabric, quality-rejection loops that consume months, and multi-hop job-work chains where the goods pass through spinning, dyeing, weaving, and finishing units without a single-owner view of the clock.
How does the 1-year clock interact with textile-specific dispatch patterns like yarn to knitting or greige fabric to processing?
The clock starts on the date the delivery challan is issued for outward movement from the principal's premises. For a Coimbatore or Tiruppur spinning-integrated mill dispatching yarn to an external knitter, the Day 0 is the challan date on the yarn dispatch, not the date the knitter receives it, not the date the knit fabric is dispatched back, and not the date the fabric arrives at the principal's warehouse. Textile chains face two structural pressures against the 1-year clock. First, seasonality — a spring-summer collection dispatched to knitter in July may not have finished-fabric receipt until March next year, which sits comfortably inside 1 year only if there are no interruptions. Second, multi-hop movement — under Section 143, the principal can dispatch inputs to job-worker A, who can dispatch to job-worker B directly under the principal's authorisation without the goods returning to the principal in between, but the 1-year clock still runs from the original dispatch date at the principal's premises. If yarn goes principal → knitter → dyer → finisher and comes back only after the finisher, the clock has been running the whole time. Every hop adds risk, and every hop must be tracked in the principal's pending-balance register.
What is the GST and interest liability if inputs are not received back within 1 year?
The GST liability is computed on the taxable value of the inputs as though the original dispatch were an outward supply. For yarn sent under Section 143 at a taxable value of ₹18 lakh with GST rate 12% for cotton yarn, the deemed-supply tax is ₹2.16 lakh — split as CGST plus SGST for intra-state or IGST for inter-state as per the place-of-supply rules applied to the original dispatch. Section 50 interest at 18% per annum accrues on the tax amount from the original dispatch date to the date of payment. For a one-year delay, the interest works out to roughly 18% of the tax, so ₹0.39 lakh on the ₹2.16 lakh in this example — meaning total exposure at the anniversary is about ₹2.55 lakh on ₹18 lakh of dispatched value, i.e., 14 percent of dispatched value crystallises as a hard cash liability. The principal must self-assess and pay this liability in the GSTR-3B for the month in which the anniversary falls, and disclose the deemed-supply movement in GSTR-1 for the same period. Failure to self-assess triggers Section 73 or Section 74 proceedings on top of the tax and interest — a Section 74 finding for suppression adds a 100% penalty.
How does the pending-balance reconciliation register catch the clock before it expires?
The register keys off the delivery challan file. Every outward challan issued under Rule 55 for job-work movement creates a row: challan number, challan date, job-worker GSTIN, HSN, description, quantity dispatched, taxable value, expected return date (challan date + defined turnaround for the process), and the 1-year statutory deadline. As inward return challans arrive from the job-worker, the register consumes the pending balance — matched by challan reference at line-item level. The reconciliation must be quantity-based, not value-based, because textile job-work loses weight to shrinkage, sizing, and process waste, so the goods coming back are legitimately a fraction of the goods sent out and the register must track the shrinkage allowance per process. A daily job runs a residual-balance report and flags every open challan against three thresholds — D-90 (early warning to sourcing and merchandising), D-60 (formal escalation to job-worker with return-schedule request), and D-30 (senior-management alert with contingency-planning trigger). If D-30 passes without an inward challan or a written recall notice, the principal has effectively acknowledged the deemed-supply risk and must plan the GSTR-3B self-assessment for the anniversary month. The single most important discipline is that the register is refreshed automatically from the challan file rather than manually maintained by a job-work supervisor — manual registers drift within weeks.
How does Section 143 reconciliation link to ITC-04 filing?
Form GST ITC-04 is the statutory return that reports the movement between principal and job-worker under Rule 45(3). Every principal who has sent inputs or capital goods to a job-worker under Section 143 must file ITC-04, half-yearly if aggregate turnover in the preceding financial year is up to ₹5 crore and quarterly if it exceeds ₹5 crore. The return reports opening balance, inputs sent during the period, inputs received back during the period, and closing balance — reconciled at HSN level. The pending-balance register from the Section 143 reconciliation is the source of truth for ITC-04. Two structural risks flow through the linkage. First, if the ITC-04 closing balance for a period includes any line where the challan date is more than 1 year old, the return itself surfaces a deemed-supply liability that the tax officer will assess in the next audit. Second, if the ITC-04 opening balance and closing balance do not tie mathematically to the challans issued and received during the period, the return is inconsistent and invites a mismatch notice. The reconciliation discipline is to lock the pending-balance register at each ITC-04 cut-off, generate the return from the register, and re-open the register only after the return is filed.

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