13 November 2017
Dear Mr.Rohit,
RCM u/s 9(4) of CGST Act,2017 suspended till 31 march 2018 by way of Notification dated 13th of October.
The above transaction is covered u/s 9(4) but if payment is before 13th of October then RCM continues to apply.
If it falls on or after 13th of October then RCM will not be attracted.
Regards
B Vinay Reddy
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13 November 2017
if we have rent paid for the m/o Sept 17 on date 28/9/17 then RCM applicable on rent and we hadn't shown in 3b due date Oct 17 and not deposit RCM now RCM suspended upto March
20 July 2025
Background: Your firm pays rent for a shop (₹8,500). RCM on rent under Section 9(4) of CGST Act, 2017 was suspended from 13th October 2017 till 31st March 2018 by notification. Rent payment for September 2017 was on 28th September 2017 — before suspension date. You did not pay RCM for that period nor declared it in GSTR-3B for October 2017. Key Points: RCM Applicability for Rent: Before 13th October 2017, RCM was applicable on rent paid to unregistered persons. From 13th October 2017 to 31st March 2018, RCM on rent was suspended (no RCM liability). Your Case (Sept 2017 payment): Since rent payment was on 28th Sept 2017 (before suspension), RCM was applicable. You should have deposited RCM in Oct 2017. What if RCM was not paid? Technically, you are liable to pay the RCM amount along with interest for late payment. Interest is calculated from the due date of payment till actual payment date. Can you skip RCM payment now because of suspension later? No, suspension applies only from 13th October 2017 onwards. Past RCM liability before suspension must be cleared. What Should You Do Now? Calculate the RCM amount for the Sept 2017 rent (8500 × applicable GST rate). Deposit the RCM amount immediately with applicable interest for delay. File a revised GSTR-3B or include the RCM amount in your next return with interest. Summary Table: Date of Rent Payment RCM Applicability Action Required Before 13 Oct 2017 RCM applicable on rent Deposit RCM + interest immediately From 13 Oct 2017 to 31 Mar 2018 RCM suspended No RCM payment required After 31 Mar 2018 RCM applicable again (unless changed) Deposit RCM as usual