NIL RETURNS QUERY

Joy,

I beg to differ from earlier replies.

Non-commencement of Business has no link with GST.

Your client could be obtaining government /local body licences or signing distribution rights before they could legally start a trade or service.

Client would still be availing services and taxability needs to be checked for each.

Re: Office Rent - (assuming this is lease of Non-residential property)

If your Client's Service supplier (landlord) is GST registered then they will raise an invoice and charge GST for which ITC would auto populate in your client's GSTR 2A for July & August, after supplier files their GSTR 1 for each month.

If the Supplier is URD, Supplier can avoid charging GST if their Income from Commercial rent is under Rs 20Lacs per annum.

Your client is availing Service from URD and needs to pay 18% GST on RCM basis and Service Descripttion would be "Rental or leasing services involving own or leased non-residential property (SAC 997212)". 

RCM Invoice needs to be drawn on the earliest of the following three days:

• any day of the month specified in lease agreement on which rent becomes due
• on 30 days from completion of month (i.e. completion of service)
• the day rent is paid to supplier.

Hope this helps.