RCM Applicability on NBFC or not.

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This query is : Resolved

Suresh S. Tejwani (Querist)

15 February 2025 If Person is Unregistered in GST & Providing DSA Service and having 70 lakh commission income it is required to get registered under GST Act or RCM Provision is apply on NBFC.

Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)

12 August 2025 Scenario:
An unregistered person is providing DSA (Direct Selling Agent) services to an NBFC.

The unregistered DSA earns commission income of Rs. 70 lakhs.

Question: Does the NBFC have to pay GST under Reverse Charge Mechanism (RCM)? Also, is the unregistered DSA required to register under GST?

Key Points:
GST Registration for DSA (Service Provider):

If the unregistered DSA’s aggregate turnover (including commission income) exceeds Rs. 20 lakhs (Rs. 10 lakhs for special category states), then the DSA must register under GST.

Since the DSA’s commission is Rs. 70 lakhs, they must get registered under GST.

RCM on NBFC (Recipient):

As per GST law, services supplied by an unregistered person to a registered person (here NBFC is registered) are subject to RCM.

This means NBFC has to pay GST on commission received from unregistered DSA under reverse charge.

NBFC will pay GST under RCM and can claim ITC if eligible.

Summary:

Unregistered DSA with Rs. 70 lakh commission must register under GST.

Until registration is done, NBFC must pay GST under RCM on commission paid to DSA.

Once DSA is registered, they will issue GST invoices and charge GST normally; then NBFC will pay GST on outward supplies as per normal procedure (no RCM).

Final Note:
It’s advisable for the DSA to get registered to avoid GST liability under RCM on NBFC.

NBFC should ensure proper compliance on RCM and claim ITC accordingly.

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