Erroneous filing of RCM sales under Nil.

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Veena Nair

21 Points Posted on 27 September 2025

If the transportation service was filed under Nil instead of RCM by the service provider, but LR copies for all the bills have been issued along with invoices. Would the service provider then become liable?

I have explained to the GST officer that :

1. our service of transportation falls under RCM

2. I have showed him our invoices which state that tax is to be paid by the recipient on transportation, the LR copies, the declarations from customers who have accepted their responsibility under RCM and paid the tax as well.

3. we have written up our entire explanation along with a similar case study.

But the officer claims that our findings and explanations are not acceptable. And that he believes that we are trying to evade tax by wrongly filing the RCM sales.

I am unable to convince the officer to accept my response. Please suggest a way to get through to the officer?

Replies (2)

Rama chary Rachakonda

Master in Accounts & high court Advocate

7021 Points Posted on 30 September 2025

To get through to the officer, you could request a review of the documents you have submitted to reaffirm the applicability of RCM.

Ask for a written communication from the officer detailing the specific reasons for non-acceptance of your explanation.

Consider escalating the matter to a higher authority or seeking professional advice if the issue persists.

Rushabh

Automation Expert

10733 Points Posted on 14 November 2026

Issuing an LR does not, by itself, make the transporter liable to pay GST. If the supply is genuinely GTA service—i.e., the transporter issued a consignment note—and it falls within the applicable RCM entry, the recipient is generally liable, subject to the entry’s conditions and exclusions. The key issue is therefore not that the return was marked “Nil”, but whether the documents and facts establish GTA service and the recipient’s RCM liability. If you merely transported goods without issuing a consignment note, the GTA RCM entry may not apply.

Submit a concise, invoice-wise reconciliation of the relevant GSTR-1/other return disclosures, invoices, LRs/consignment notes, recipients and evidence of recipients’ RCM payment. Explain precisely what “Nil” means in the return and correct any reporting inconsistency through the permitted procedure, if required; do not rely only on customer declarations.
Cite the exact RCM notification entry and show how each condition is met, including the recipient category and any applicable option/forward-charge position. An LR may support the evidence, but the officer may dispute whether it contains the particulars necessary to qualify as a consignment note.
Ask the officer to identify the specific statutory condition or document they consider unmet, and respond point-by-point in writing. If an adverse order is passed, preserve the hearing record and appeal within the statutory time limit; the applicable route depends on whether this is an audit/query, notice or adjudication order.

This issue is best handled as a documented reconciliation of GTA status, return reporting and recipient tax payment. Manual review across invoices, LRs and customer evidence is difficult; automation can reduce repetitive work while leaving classification and legal judgment in professional hands. 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 the workflow: https://wa.me/message/3HVOZ7HIY4ESC1