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RCM Under GST: Complete List of Services, Calculation, and Compliance 2025

  • Writer: sai krishna
    sai krishna
  • Jun 7
  • 2 min read

Reverse Charge Mechanism (RCM) means the recipient of goods or services — not the supplier — is liable to pay GST directly to the government. This is a critical compliance area that frequently comes up in GST audits.

Which Services Attract RCM Under Section 9(3)?

The following services are notified under Section 9(3) of CGST Act (Notification 13/2017-CT(R)):

1. Goods Transport Agency (GTA) services — when recipient is a registered person 2. Legal services by an advocate — when recipient is a business entity 3. Services by a director to a company 4. Insurance agent services 5. Recovery agent services 6. Author/composer services to a publisher 7. Renting of motor vehicles (specified cases) 8. Services of security personnel by non-body corporate to a body corporate 9. Services by government or local authority (excluding certain specified services)

Important: GTA services are the most frequently missed RCM liability in audits.

GTA RCM — Detailed Compliance

If you pay freight to a transport company (GTA), and the GTA has not opted for forward charge (i.e., they have not issued a GST invoice with tax), you must pay 5% GST on the freight amount under RCM.

How to Pay RCM

1. Calculate RCM liability for each month 2. Pay only through Electronic Cash Ledger (ECL) — no ITC can be used to pay RCM 3. File in GSTR-3B Table 3.1(d) — Inward supplies attracting RCM 4. Claim ITC of RCM paid in Table 4(A)(3) of GSTR-3B in the same or subsequent month

Common RCM Audit Findings

- GTA payments not identified and RCM not discharged - Advocate fees paid without discharging RCM - Security service payments to non-body-corporate firms without RCM - Rent paid to unregistered landlord — wrongly classified as non-taxable

RCM Under Section 9(4) — Supplies from Unregistered Dealers

Under Section 9(4), if a GST-registered person purchases goods or services from an unregistered dealer, RCM applies. However, this is currently suspended for most supplies except specific notified categories.

Interest on RCM Default

If RCM is not paid on time, interest under Section 50 at 18% per annum applies from the due date of payment to the actual date of payment. This is a key demand item in GST audits.

Disclaimer: Consult your CA for case-specific advice. RCM notifications are amended periodically.

 
 
 

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