GST AND TDS COMBINED

IF A CA RAISES A COMBINED BILL FOR SERVICE AND REMIMBURSEMENT OF EXPENSES. SHOULD HE CHARGE GST ON THE WHOLE BILL AND ON WHICH AMOUNT SHOULD BE TDS DEDUCTED?

Replies (4)
Quick Summary
This discussion clarifies how to handle GST and TDS when a Chartered Accountant issues a combined bill for services and expense reimbursements. It explains that GST should typically be charged only on the service amount, provided the 'pure agent' conditions are met for expense reimbursements. Regarding TDS, the consensus is that it should be deducted on the entire bill amount, including reimbursements, as the CA themselves cannot deduct TDS under the CGST Act.

 First of all, CA cannot deduct TDS under CGST Act.

Only specified Government entities can deduct TDS under Section 51 of CGST Act.

2.  GST can be charged amount excluding the reimbursement of Expenses. Reimbursement of Expenses is only allowed in GST when condition of Pure Agent is satisfied as per Rule 33 of CGST Rule.

YES A CA CAN NOT DEDUCT TDS BUT WILL THE CLIENT DEDUCT TDS ON THE WHOLE BILL AMOUNT OR ONLY ON THE VALUE OF SERVICE.

ON WHICH AMOUNT SHOULD BE TDS DEDUCTED?

Deduct TDS on Whole amount (on basic value)..
If he can't accept then ask separate bill...

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.

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