Effective date & Liability to pay

As per notification no. 09/2024,dated 08/10/2024 central tax rate, rcm is applicable for any rent other than dwelling residential property, w. e. f. 10/10/2024

We paid warehouse rent on 09/10/2024, for the month of October 2024

can we are liable to pay rcm for October, 2024 rent paid on 09/10/2024

please guide
Replies (3)
Quick Summary
This discussion clarifies the applicability of the Reverse Charge Mechanism (RCM) on warehouse rent following notification 09/2024, effective from 10th October 2024. For rent paid on 9th October 2024 for the month of October, RCM is generally not applicable as the payment predates the effective date. However, RCM will apply to subsequent payments for non-residential property rent from November 2024 onwards. The nuances of rent pertaining to a period versus payment date are discussed, with a recommendation to seek professional tax advice.

Based on the notification, RCM (Reverse Charge Mechanism) is applicable for rent on non-residential properties, effective 10/10/2024. Since you paid warehouse rent on 09/10/2024, for the month of October 2024, you are not liable to pay RCM for this specific payment. Here's why: - The RCM notification is effective from 10/10/2024. - Your payment was made on 09/10/2024, which is before the effective date. - The rent is for the month of October 2024, but the payment was made in September, so it falls under the old rules. However, keep in mind that from November 2024 onwards, RCM will be applicable for rent on non-residential properties, including warehouse rent. Ensure you factor this in for future payments. Please consult a tax professional or expert to confirm this interpretation and ensure compliance with GST regulations.

But sir rent is paid specific for October 2024 to landlord, on 09/10/24.

Notification is effective fron 10/10/2024

My understanding is though rent paid on 09/10/24
but rent is pertaining to Oct. 24, & we are consuming service whole October 24 month.

If rent period is up to 09/10/24, then it is ok, rcm is not applicable.

In this scenario what is the legal angle of this situation.

If the warehouse is non-residential and the landlord is an unregistered person, RCM does not apply to this rent for October 2024. Notification 09/2024-Central Tax (Rate) took effect from 10 October 2024. Under GST time-of-supply rules for services, where the invoice is issued within the prescribed period, the relevant date is generally the earlier of the invoice date and payment date. Since you paid on 9 October, the time of supply falls before the notification’s effective date, even though the rent relates to October.

This assumes the rent payment was made to the landlord on 9 October and the invoice, if issued, does not establish an earlier time of supply. If the landlord is registered, the usual forward-charge treatment applies; check the invoice and payment records to confirm the position.

Rent compliance depends on matching the lease period, invoice date, payment date and supplier’s registration status. Manual tracking across rent ledgers and GST returns is difficult; automation reduces 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%. For a workflow discussion, connect with us on WhatsApp: https://wa.me/message/3HVOZ7HIY4ESC1

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