
Reverse Charge Mechanism Under GST — The Notified List (GTA Freight, Legal, Security, Director, Rent from Unregistered Landlords, Metal Scrap, Imports of Services), Section 9(4) Today, Time of Supply, Self-Invoicing Within 30 Days, Paying in Cash and Claiming the Credit, and the Accounting Entries
Video Explanation & Insights
GST on freight: when reverse charge applies and who must register
4 videos on this topic
What reverse charge is
Normally the supplier collects GST and pays it to the government. Under reverse charge the recipient pays the tax directly — either because the supply is on the notified list under section 9(3) of the CGST Act (and section 5(3) of the IGST Act), or, under section 9(4), because a notified class of registered recipients buys specified goods or services from unregistered suppliers. The recipient pays the tax in cash through GSTR-3B Table 3.1(d), and if the supply is used for business, takes credit of the same amount in Table 4 of the same return — the net cash cost is nil for a fully taxable business, but the compliance is mandatory and interest runs on any RCM paid late.
Section 9(3): the notified supplies
| Supply | Supplier | Recipient who pays | Rate |
|---|---|---|---|
| Goods transport agency (GTA) services | GTA that has not opted to pay tax itself | Factory, society, registered person, body corporate, partnership firm, casual taxable person | 5% (no credit to the GTA); a GTA may opt for forward charge at 5% or 18% for the year by declaration |
| Legal services | Individual advocate, firm of advocates, senior advocate | Any business entity | 18% |
| Arbitral tribunal services | Tribunal | Business entity | 18% |
| Sponsorship | Any person | Body corporate or partnership firm | 18% |
| Services of government or local authority (other than renting of immovable property, post, transport of goods/passengers) | Government | Business entity | As applicable |
| Renting of immovable property by government | Central/State Government, UT, local authority | Registered person | 18% |
| Renting of commercial property (other than residential) | Unregistered person | Registered person (from 10 October 2024) | 18% |
| Renting of residential dwelling | Any person | Registered person (except a proprietor renting for personal residence) | 18% |
| Services by a director | Director (other than under an employment contract) | The company or body corporate | 18% |
| Insurance agent, recovery agent, DSA (individual/HUF/firm) | Agent | Insurer, bank, NBFC | 18% |
| Security services (personnel) | Any person other than a body corporate | Registered person (not government departments or composition dealers) | 18% |
| Renting of motor vehicle for passengers (fuel cost included) | Non-body-corporate supplier charging 5% without credit | Body corporate | 5% |
| Import of services | Supplier outside India | Any person located in India (business) | IGST at the applicable rate |
| Copyright transfer by author, music composer, artist | Author etc. | Publisher, music company, producer | 12% / 18% as applicable |
| Goods: cashew nuts (raw), bidi wrapper leaves, tobacco leaves, raw cotton, silk yarn, lottery, used vehicles/seized goods sold by government, priority sector lending certificates | Agriculturist / government / registered person | Registered recipient | As notified |
| Metal scrap (chapters 72–81) | Unregistered person | Registered person (from 10 October 2024); registered-to-registered sales carry 2% TDS instead | 18% |
Purchases from unregistered persons today
- •The blanket 2017 rule — every purchase from an unregistered supplier taxable in the buyer's hands — was suspended from 13 October 2017 and replaced from 1 February 2019 by a narrow version: only notified classes of registered persons pay RCM on notified goods and services from unregistered suppliers.
- •The only class notified so far is real-estate promoters: cement bought from unregistered suppliers, capital goods, and the shortfall below the 80% registered-purchase requirement for residential projects, plus development rights and FSI.
- •For everyone else, buying from an unregistered vendor carries no GST — but the vendor's turnover may itself exceed the threshold, and the expense still needs a proper voucher for income-tax purposes.
- •Reverse charge and composition: a composition dealer pays RCM at the normal rate on notified supplies and gets no credit of it.
Time of supply, invoice, payment and credit
- 1Time of supply — services: the earlier of the date of payment or 60 days from the supplier's invoice date; goods: the earlier of receipt, payment or 30 days from invoice. If the supplier is unregistered, the date you raise the self-invoice governs.
- 2Self-invoice: rule 47A (from 1 November 2024) requires the recipient to issue a tax invoice within 30 days of receiving a supply from an unregistered person; also issue a payment voucher on payment. For registered suppliers (advocate firms, GTA with GSTIN), their invoice marked 'tax payable under reverse charge' suffices.
- 3Report and pay in GSTR-3B Table 3.1(d) in the month of the time of supply; the liability can be discharged only from the electronic cash ledger.
- 4Claim credit in Table 4(A)(3) of the same GSTR-3B (import of services in 4(A)(2)) if the supply is used for business and not blocked under section 17(5); a self-invoice supports credit only if the tax has actually been paid.
- 5Late payment: interest at 18% from the due date; credit claimed late is subject to the section 16(4) time limit but a self-invoice issued late (after the 30 days) is penalised under section 122.
Entries in Tally / your ERP
| Event | Entry |
|---|---|
| Freight bill ₹10,000 from a GTA (RCM 5%) | Dr Freight ₹10,000 / Cr GTA ₹10,000; RCM: Dr Input CGST 250 + Input SGST 250 / Cr Output CGST (RCM) 250 + Output SGST (RCM) 250 — in Tally, enable 'reverse charge applicable' on the ledger and raise the tax liability through the journal (Stat Adjustment → Increase of Tax Liability & ITC) |
| Rent ₹50,000 to an unregistered landlord (18%) | Dr Rent 50,000 / Cr Landlord 50,000; Dr Input CGST 4,500 + SGST 4,500 / Cr Output CGST (RCM) 4,500 + SGST (RCM) 4,500 |
| Foreign software ₹1,00,000 (IGST 18%) | Dr Software / Cr Vendor; Dr Input IGST 18,000 / Cr Output IGST (RCM) 18,000; remit with 15CA/15CB and section 195 TDS as applicable |
| Payment of RCM | Dr Output CGST/SGST (RCM) / Cr Bank (through the cash ledger challan) |
| Composition dealer | The RCM tax is debited to the expense (no input ledger) |
Reverse charge: questions we are asked
No. RCM applies to a goods transport agency that issues a consignment note; a truck owner hiring out the vehicle without one is not a GTA and the service is exempt.
Yes, since 10 October 2024 — 18% under reverse charge if you are registered; credit is available if the shop is used for taxable business.
No. It must be paid in cash; the credit of that payment is then available against your output tax.
Pay through DRC-03 with interest at 18%; credit can be claimed only within the section 16(4) time limit, so old RCM often becomes a pure cost.
No. GST TDS (2%) is deducted by government buyers and, since October 2024, by registered buyers of metal scrap; it is credited to your cash ledger, not a reverse charge.
Yes — expense-head mapping, self-invoicing, monthly RCM working, credit claims and DRC-03 regularisation of past periods.