CBIC Clarification on Section 16(4) Time Limit in respect of RCM supplies from unregistered persons

In such cases, the relevant Financial Year for calculation of time limit for availment of ITC Under section 16(4) of CGST Act, 2017 will be the Financial Year in which invoice has been issued by the recipient, subject to payment of tax and other conditions/restrictions of Section 16 and 17 of CGST Act

In case, the recipient issues the invoice after the time of supply of the said supply and pays tax accordingly, he will be required to pay interest on such delayed payment of tax and may also be liable to penal action under the provisions of Section 122 of the CGST Act.

Source : CBIC