Input Tax recovery against RCM is subject to normal input recovery rules ie time limit for claiming an input as per Art 55 DL applies to this as well. If 2 tax periods have expired from the date of invoice the input would not be normally permitted. Hence for recovering the same Voluntary Disclosure would be required. Please note that FTA has not specifically stated on such missed out RCM recognition. This is just a view.

Agree on this view. Although this will be a hardship on the tax payer to file VD on missing RCM transactions regardless of the amount.

Yes Bhavya, it would cause hardship. Ideal way would be to do a VD and claim input. One can try argument that VD is not required since VAT payable position does not get affected but that is a far fetched argument due to time limitation for recovering input. On another note, the CD for Administrative Penalties does not specifically state penalty for non recognition of VAT on import of services (it does specifically state for import of Goods). I could be wrong. So not sure what the official stand of FTA on import of services is.