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Industries · Steel & Metal Trading

Steel & Metal Trading

ITC reconciliation at volume, scrap RCM, e-way bills, TDS on purchases

Volume and margin explain nearly every compliance problem in this trade. A mid-sized TMT or structural steel dealer books hundreds of purchase invoices a month across mills, stockists and traders, moves goods on dozens of e-way bills, and issues credit notes for rate differences and weight shortages that must be matched back to the original invoice in a later period. On a 2 to 4% gross margin, an 18% credit denial on a single consignment costs several times the profit on that deal.

We run reconciliation as an operation rather than a task: purchase register against GSTR-2B before the 20th with a supplier-wise exception list issued early enough to chase, IMS actions taken inside the window, credit notes tracked to their original invoice, e-way bill controls built into despatch, scrap reverse charge and GSTR-7 where they apply, and a per-supplier tracker so TDS on purchases begins on the right invoice.

Compliance challenges we solve

  • GSTR-2B reconciliation at volume

    Section 16(2)(aa) makes 2B appearance a condition and GSTR-3B has been hard-locked since July 2025. Matching has to run at invoice, GSTIN-summary and ledger level.

  • Scrap under reverse charge and GST TDS

    Since 10 October 2024, scrap under Chapters 72 to 81 bought from an unregistered supplier attracts RCM; registered-to-registered supply above ₹2.5 lakh attracts 2% GST TDS.

  • E-way bills on bulk movement

    One day per 200 km from Part-B entry, extension only within eight hours either side of expiry, and section 129 detention means tax plus an equal penalty before release.

  • Working capital in the credit ledger

    Stock turning in 60 days parks roughly two months of input tax permanently, and refund is not available for simple accumulation. We measure it as a share of your working capital.

Why volume and margin drive everything

Volume means reconciliation is not a task but an operation. At several hundred purchase invoices a month, manual matching does not merely take longer — it fails differently, because the errors hide in the tail. A supplier who files under the wrong GSTIN, or as B2C, or in the wrong period, shows as missing at invoice level and matched at summary level, which is why the match has to run at three levels rather than one.

Margin means there is no cushion. Two to four per cent gross on a ₹1 crore consignment is ₹2 to ₹4 lakh; an 18% credit denial on the same consignment is ₹18 lakh. It also means a large slice of working capital lives permanently in the electronic credit ledger, funded by borrowing and earning nothing.

Input tax credit and the reconciliation discipline

Since 1 January 2022, section 16(2)(aa) makes credit available only where the supplier has furnished the details and they appear in your GSTR-2B. The Invoice Management System introduced in October 2024 lets you accept, reject or hold invoices before 2B is generated, which is genuinely useful — but only if someone acts inside the window. From July 2025 the auto-populated liability in GSTR-3B is hard-locked, so claiming provisional credit and sorting it out afterwards is no longer available.

Inverted duty is rarely the issue in steel, where input and output are typically both at 18%. The accumulation is a timing problem: you pay tax on purchases now and recover it as stock sells, so a 60-day stock turn parks about two months of input tax permanently. Refund is not available for simple accumulation, so the only levers are supplier discipline, purchase timing and stock turn.

Scrap, e-way bills and TDS on purchases

Two separate mechanisms apply to metal scrap under Chapters 72 to 81 since 10 October 2024: reverse charge on a registered buyer purchasing from an unregistered supplier, and 2% GST TDS where both sides are registered and the contract value exceeds ₹2.5 lakh. The second requires a deductor registration and monthly GSTR-7 by the 10th, which traders dealing in scrap alongside their main line routinely miss.

On the road, e-way bill validity is one day per 200 km (one day per 20 km for over-dimensional cargo) counted from Part-B entry. Since 1 January 2025 an e-way bill cannot be generated against a document dated more than 180 days earlier, and total validity cannot extend beyond 360 days from generation. On direct tax, TDS on purchases at 0.1% above ₹50 lakh per seller applies where your prior-year turnover exceeded ₹10 crore, with 30% disallowance for failure to deduct.

Frequently asked

A supplier has not filed his GSTR-1 and my credit is stuck. What are my options?+

Legally, section 16(2)(aa) makes appearance in GSTR-2B a condition, so the credit is not available until he files. Commercially, your leverage is the unpaid tax component of his invoice — the practice we set up is to release the taxable value on schedule and the GST component only once the invoice reflects in 2B. Courts have occasionally granted relief where the buyer proved payment and genuineness and the supplier had absconded, but those are hard-fought exceptions, not a plan.

I buy scrap from local kabadis who have no GST number. What do I have to do?+

Since 10 October 2024, purchases of metal scrap under Chapters 72 to 81 from an unregistered person by a registered person are under reverse charge. You raise a self-invoice, pay the tax in cash — it cannot be set off from the credit ledger — and then claim it as input credit in the same or a subsequent period. Missing this is one of the more common findings in scrutiny of metal traders, and interest runs from the original due date.

When do I need a GST TDS deductor registration?+

Where you buy metal scrap from a registered supplier, GST TDS at 2% applies under Notification 25/2024-CT if the value of supply under the contract exceeds ₹2.5 lakh. That requires a separate registration as a deductor, filing GSTR-7 by the 10th of the following month and issuing a TDS certificate to the supplier. Traders who deal in scrap alongside their main line usually discover this only when a supplier asks where his TDS credit has gone.

My truck was detained because the e-way bill expired. Can I just extend it?+

Extension is only possible in the window from eight hours before expiry to eight hours after. Once that closes you are into section 129 territory, which means tax plus an equal penalty before the vehicle is released. Validity is one day per 200 km from the time Part-B is entered, so entering Part-B at despatch rather than at loading, and monitoring expiry on the road, prevents most of these.

Do I still collect TCS on sales as well as deduct TDS on purchases?+

TCS on sale of goods under the old section 206C(1H) was withdrawn with effect from 1 April 2025, so the buyer-versus-seller overlap is gone. What remains is TDS on purchases under section 393(1) Table Sl. 8(ii), formerly 194Q — 0.1% on purchases from a resident seller above ₹50 lakh in aggregate for the year, on the value in excess of ₹50 lakh, excluding separately shown GST, where your preceding-year turnover exceeded ₹10 crore. TCS on scrap under the separate section 206C entry continues.

What happens if I fail to deduct TDS on purchases?+

Failure to deduct under section 393(1) Sl. 8(ii) triggers disallowance of 30% of the purchase value, which for a steel trader is catastrophic relative to profit. The control is a rolling annual tracker per supplier so the ₹50 lakh threshold is caught on the invoice that crosses it, not at year end when the deduction can no longer be made cleanly.

My net margin is around 2.5%. Does that force a tax audit?+

Possibly. Under section 63 of the Income-tax Act 2025, audit is required above ₹1 crore of turnover, or ₹10 crore where cash receipts and cash payments are each within 5%. Many commentators read section 63 as also creating a standalone trigger where an eligible assessee declares profit below the deemed rate under section 58, regardless of prior opting-in. That reading is contested and untested. Above ₹10 crore you are audited on the turnover limb anyway — the real work is stock and gross-profit documentation.

Is there a deadline after which I can no longer file an old return?+

Yes. A three-year outer limit on filing returns is in force from 1 July 2025, operationalised from the October 2025 tax period: once a return period is more than three years past due, the portal will not accept it. For traders carrying old unreconciled periods, that clock has already started, which is why an ITC recovery review on past periods is usually the first thing we run.

Specialist compliance for steel & metal trading.

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