Regarding RCM

This query is : Resolved

jignesh sitapara (Querist)
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22 February 2021 I am tax consultant of GST. Now, I raise invoice to my customer, Than they have to pay RCM against my invoice ? I have not gst registration, because my annual income apporx 8 lacs.

CA Altamush Zafar

CA Altamush Zafar (Expert)
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23 February 2021 If you are an advocate then they have to pay rcm otherwise there is no liability

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Asha Kanta Sharma

Asha Kanta Sharma (Expert)
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20 July 2025 Your Situation:
You are a tax consultant (service provider).
Your annual turnover is approx ₹8 lakhs, so you are not required to register for GST (threshold for registration is ₹20 lakhs or ₹10 lakhs in special category states).
You raise an invoice to your customer without GST, since you are unregistered.
Key Points about Reverse Charge Mechanism (RCM):
When does RCM apply?
Under GST law, certain specified services (like legal services, goods transport services, sponsorship, etc.) attract reverse charge, where the recipient of the service is liable to pay GST instead of the supplier.
Is consulting service covered under RCM?
Normally, general consulting services do not attract RCM unless specifically notified.
If you are unregistered and provide services to a registered customer:
Your customer may have to pay GST under RCM only if the service is covered under the notified categories for reverse charge.
For normal tax consultancy services, RCM is not applicable.
Hence, your customer does NOT have to pay GST on your invoice under RCM.
What if your customer insists on paying GST under RCM?
You can check if your service is covered under RCM notified services.
If not, your customer cannot pay GST on your behalf.
Your obligation:
Since you are unregistered (below threshold), you cannot charge GST.
You cannot issue a GST invoice.
Summary:
Situation Explanation
You (unregistered) raise invoice No GST charged
Customer (registered) pays GST? Only if service is notified under RCM, else No
Normal consulting services Generally NOT under RCM
Your customer’s liability No GST under RCM on your invoice normally

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