RCM 9(4) on Payment to Contractor who sends labourers

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Sivaraman A R (Querist)
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19 August 2025 Client a Builder/Developer doing Real estate project under JDA with Land owner.A contractor will send many labourers.Builder pays to contractor and deduct TDS under IT Act 194C.Contractor has no GST.

Will this payment to contractor needs to be considered in80:20ratio of mandatory requirement of purchase from regd dealer?

If 80% requirement failed, whether liable to RCM 9(4)?

How to structure to avoid RCM for this?

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