Finance/Compliance Consultant
72926 Points
Posted on 07 November 2026
GST and TDS on a CA's combined bill:
• GST: the full bill (fees + reimbursements) is the value of supply (Sec 15(2)(c), incidental expenses), unless the reimbursements qualify as pure-agent costs (Rule 33). For example: ROC fees, court fees or stamp duty paid on the client's behalf, at actuals, shown separately, where the client is the actual recipient of the government service. Pure-agent items are excluded from the GST value.
• Travel and OPE (hotel, conveyance incurred by the CA for his own work) aren't pure-agent items, so GST applies on them.
• TDS: Sec 194J on the whole bill, including reimbursements (CBDT Circular 715/1995 Q30), excluding GST shown separately (Circular 23/2017). Pure statutory fees (ROC, stamp duty) paid at actuals are sometimes excluded in practice if separately billed and supported, but the Circular view is to deduct on the full amount.