Chartered Accountant
39039 Points
Joined September 2008
RCM Postponement - Applicability
1. There were 2 main provisions- one copied from Service Tax - Sec 9(3) - GTA, Advocates, Foreign services recived- this continues- no change as of now.
2. The second was unregistered suppliers reciepts by any GST registered person to be liable on RCM from 1st July under 9(4). Relief provided by way of 5K per day per registration. This provision has been kept in abeyance till 31st march 2018 as the concept brings out errant suppliers not in the mainstream who evade/ underinvoice. This is from 12th October.
Question is from 1.7 to 12.10 the amendment does not specify that there wouldbe no liability. However 80% in numbers would not have complied with the RCM and 20% would have. In 80% some may want to be safe and not face demand.
The advice is if credit is available and can be utilised- to avoid a possible demand- one can for compliance- cost will be only compliance.
In the interim ask industry to ask for waiver in period of 1.7 to 12.10 as those who have complied - 90% wouldhave availed credit. This would helpthe SME- otherwsie after a few years the demand on the same rleif provided would come. This exemption should be asked to be made retrospective clearly.