20 July 2025
Great questions. Let's break both down clearly:
โ 1. Is a Registered Dealer liable to pay GST under RCM on all purchases/expenses from Unregistered Dealers? No, a registered dealer is not required to pay GST under RCM on all purchases from unregistered dealers, as a general rule under the current GST regime (as of now in 2025).
๐ Background:
Initially, under Section 9(4) of the CGST Act, GST under RCM was applicable on all supplies from unregistered persons to registered persons.
But this provision was suspended and then restricted via notifications.
โ Current Position (as of 2025):
GST under RCM on purchases from unregistered dealers is applicable only in specific notified cases, such as:
Specified categories of goods/services (e.g., cashew nuts, bidi wrapper leaves, etc.) Real estate sector โ purchases by promoters from unregistered persons exceeding 20% of total input value. ๐ก In general, casual day-to-day purchases from unregistered dealers do not attract RCM for most businesses. โ 2. If a person is engaged only in Exempted Goods Business, does RCM still apply to them? No, if a person is engaged only in supplying exempted goods, they are not liable to pay GST, and thus RCM also doesnโt apply in the practical sense.
๐ Why?
A person dealing only in exempted goods/services is not liable to be registered under GST (unless they cross certain threshold for inter-state supplies or fall into special categories). RCM liability arises only if the recipient is a registered person under GST. ๐ So, if the person is not registered, RCM does not apply to them at all.