GSTR-1 Late Fee Recovery: Legal Position
Can a proper officer manually recover Section 47 late fee through DRC-01, DRC-01D, DRC-07 or Sections 78–79 when the GST portal did not collect it?
The central interpretation
Section 47 creates late-fee liability, but late fee remains distinct from tax, interest and penalty. The department must identify a specific statutory and procedural route before starting officer-initiated determination or recovery.
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