Consortium Partnership: GST and TDS query

Q1: Should Partner A raise invoice on Partner B? Will it attract GST?

👉 NO.
Partner A is supplying service to HPCL, not B.
Raise RCM invoice to HPCL (even if payment flows through B).
No GST on settlement with B.

Q2: Is the receipt from B considered share of consortium partnership? Is 194T applicable?

👉 NO.
It is A’s own revenue, not a profit share.
👉 Section 194T does NOT apply.
No TDS is applicable.

The GST and TDS treatment turns on who is actually supplying the tanker service to HPCL—not simply who receives the payment. On the stated facts, each owner appears to operate and bear the risk of their own truck, and each truck serves its owner’s pump. If HPCL’s contract/work orders and trip records also identify Partner A as the supplier for A’s trips, A should generally account for the freight as its own service income; B’s receipt and remittance would then be a collection/settlement arrangement, not a share of consortium profit. A should issue the required invoice to HPCL (or document the agreed invoicing arrangement) rather than treat the receipt as a mere consortium distribution. The RCM liability, if applicable to the actual service and recipient, is ordinarily the recipient’s; confirm the contract and invoice flow before determining whether A must charge GST.

• If B is instead the contractual supplier to HPCL and engages A to perform transport, A’s payment from B may be consideration for a service to B. In that case, assess A’s GST registration, the applicable transport-service exemption/forward-charge/RCM provisions and the precise contractual arrangement; do not assume the HPCL RCM treatment automatically covers B’s payment to A.
• Calling the arrangement a “consortium” does not by itself make receipts a profit share. A genuine joint venture/association supplying services as a separate person can have different GST consequences; the agreement and actual conduct must support that characterization.
• Section 194T applies to payments by a firm to its partner as salary, remuneration, commission, bonus or interest, subject to its threshold and other conditions. It does not ordinarily apply merely because one consortium member remits to another the amount collected for that member’s own trips. If the consortium is a firm and the amount is in substance a specified payment by the firm to its partner, examine section 194T; if the parties are not partners in a firm, section 194T is not attracted on that basis.

The key checks are the HPCL tender/contract, whose GSTIN and name appear on invoices, who is liable to HPCL for each trip, and whether the agreement creates a separate firm or joint venture.

For tanker-service billing, aligning the contract, trip records, GST treatment and books is essential to avoid mismatches between the parties. Manual review of each trip and settlement is difficult; automation can reduce repetitive work while professional judgment remains in control. At Jir AI, our 2,000+ AI agents and 650+ integrations streamline GST, ITR, TDS, TCS and other compliance workflows, helping reduce manual workload by up to 70%. WhatsApp us to explore a workflow for your practice: https://wa.me/message/3HVOZ7HIY4ESC1