RCM Applicability on Services

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Dhawal Jaiswal (Querist)
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01 April 2025 Dear Sir,
We are manufacturing of Writing Printing Paper and for running plant there are various services which we availed. So, we need your valuable advice about RCM applicability (With Notification & Ruling) on below mentioned points:-
1. We receive commission bills from unregistered person (Against Purchase of Bagasse, Wood, Paddy & others RM). Is RCM applicable on such transaction?
2. We purchase Paddy husk (Exempted goods) from unregistered person. Some Unregistered suppliers give invoice memo and some are not giving any docs. Is self-purchase invoice required to generate and applicability of RCM?
3. We purchase some general goods (Stores Item / Stationary / Housekeeping Items & Etc) from unregistered person with Invoice memo. Is RCM applicable on such transaction?
4. We have received services related to Civil/Mechanical/Electrical & other from unregistered contractor, which is booked in books of a/c under the head of Rep & Maintenance-Mechanical/Electrical/Civil & Others related head. Is RCM applicable on such transaction?
5. We receive services related to monthly Fixed Rental of Tractor Trolly for Plant work (Within Premises) and take JCB/Hydra on hourly basis from unregistered contractor, which is booked in books of a/c under the head of Vehicle Hire-Plant. Is RCM applicable on such transaction?
6. We receive services related to loading/unloading of material within Plant, shifting/staking by tractor trolly/dumper of RM, Fuel, Lime Sludge, Ash & Others (Agreed contract based on Weight Basis/Monthly Fixed) from unregistered contractor, which is booked in books of a/c under the head of Loading/Unloading Exp, Shifting Exp, Staking Exp, disposal of Mud Exp & Etc. Is RCM applicable on such transaction?
7. We receive monthly bills from mid-level employee as retainers of Plant (Age 60+), which is booked in books of a/c under the head of Rep & Maintenance-Mechanical/Electrical & Others. Is RCM applicable on such transaction?
8. We receive monthly bills from employee (Security) as retainers (Age 60+), which is booked in books of a/c under the head of Security Expenses. Is RCM applicable on such transaction?
9. We receive monthly bills from employee as retainers (Age 60+), which is booked in books of a/c under the head of Professional & Consultancy. Is RCM applicable on such transaction?

Asha Kanta Sharma

Asha Kanta Sharma (Expert)
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12 August 2025 Hey! That’s quite a detailed query on RCM applicability for your manufacturing unit. Let me break down the answers pointwise with references to GST notifications/rulings wherever applicable:

1. Commission bills from unregistered persons (against purchase of Bagasse, Wood, Paddy & others RM)
RCM applicability:

Yes, RCM applies on services received from unregistered persons if covered under RCM notifications.

However, commission for goods purchase is considered a service. Since the supplier is unregistered, GST is applicable under RCM.

Notification: GST Notification No. 13/2017-Central Tax (Rate) - specifies services liable to RCM from unregistered persons.

2. Purchase of Paddy Husk (Exempted goods) from unregistered person; sometimes without invoice
RCM applicability:

No GST is applicable on exempted goods purchase (no GST on supply), so no RCM liability.

For inward supply without invoice, you may generate a self-invoice as per Rule 46 of CGST Rules.

Note: Self-invoice required only if supply of goods/services is taxable and no invoice is received.

3. Purchase of general goods (Stores Item/Stationery/Housekeeping) from unregistered person with invoice memo
RCM applicability:

RCM is not applicable on purchase of goods from unregistered persons (only applicable on services).

Invoice memo does not replace GST invoice but if goods are taxable, seller must be registered.

4. Services from unregistered contractors related to Civil/Mechanical/Electrical (Repairs & Maintenance)
RCM applicability:

Yes, RCM is applicable on services from unregistered contractors (repair, maintenance services) as per Notification No. 13/2017-CT(Rate).

You need to pay GST on RCM basis and report accordingly.

5. Services related to Fixed Rental of Tractor Trolley, JCB/Hydra hiring from unregistered contractor
RCM applicability:

Yes, services like hiring of machinery/vehicle fall under RCM if provided by unregistered suppliers.

Notification No. 13/2017 applies here as well.

6. Services related to loading/unloading, shifting, stacking, disposal from unregistered contractor
RCM applicability:

Yes, these services are liable for GST under RCM if received from unregistered persons (Notification 13/2017).

They are supply of service for consideration and taxable under GST.

7. Monthly bills from mid-level employee (age 60+) as retainers of Plant (Rep & Maintenance)
RCM applicability:

If the employee is a registered supplier of services, RCM applies on services received from unregistered suppliers.

If this is an employment relationship, no GST applies.

If these are professional services (contractors), then RCM applies.

8. Monthly bills from employee (Security) as retainers (Age 60+)
RCM applicability:

Similar to above, if this is contract security services from unregistered person, RCM applies (Notification 13/2017).

If employment contract, no GST.

9. Monthly bills from employee as retainers under Professional & Consultancy
RCM applicability:

RCM applies on professional services received from unregistered persons (e.g. consultancy services).

Must pay GST under RCM as per Notification No. 13/2017.

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