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GST TDS u/s 51 Applicability on RBI and it's subsidiaries

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venkateswara reddy

Senior finance and accounts

27 Points Posted on 07 November 2025

The Reserve Bank of India (RBI) is a statutory body constituted under the RBI Act, 1934. There are certain companies that are wholly owned subsidiaries of RBI (incorporated as Section 8 companies/private limited companies).

For the purpose of GST TDS applicability under Section 51 read with Notification No. 50/2018 – Central Tax dated 13.09.2018, should RBI and its 100% owned subsidiary companies be treated as “Government entities / Government-controlled bodies / PSUs”?

looking for clarity regarding GST TDS applicability under Section 51 of the CGST Act.please clarify me

Replies (2)

Quick Summary

This discussion seeks clarification on the applicability of GST TDS under Section 51 for the Reserve Bank of India and its wholly-owned subsidiaries. It questions whether these entities should be considered 'Government entities' for TDS purposes. The practical implication is understanding when GST TDS deductions are required when making payments to RBI or its subsidiaries, noting that government departments may be liable for TDS if subsidiaries provide services to them.

Aashok Kumar Sharma

Finance/Compliance Consultant

67376 Points Posted on 08 November 2025

Practical Implication for Accounts/Finance

When making payments to vendors/service providers:
- RBI itself: No GST TDS deduction unless notified.
- RBI subsidiaries (Section 8 / Pvt Ltd): No GST TDS deduction unless notified.
Keep in mind: Some RBI subsidiaries may provide services to government departments; in that case, the liability to deduct TDS falls on the government department, not on the subsidiary.