Rcm applicability after 01-oct-17

I  think RCM applicable  Up to 13/10/2017 (section9 (4) of the cgst act 2017) , please confirm  with Department  of GST .

RCM for transactions prior to 12th October 2017.

Not 38.17 sets out that the provisio to Not 8/17 [ earlier limited to 5k/ day] be omitted. The question is whether omitted from 13th October or from 1st July.

The postponement of levy till 31.3.2018 due to public interest leads ot a logical reasoning that the levy should not be there for period prior to Notification. If this reasoning is not taken, hardly anybody who was complying in the past would have complied for the month of october. Those who were wondering what to do will not go forward. It would have been ideal to clearly make the change retrospective which maybe read as intention if the word used " omitted" is analysed.

The representation for the past period waiver are with the GST Council pending for decision. 

Considerign the Govts will to iron out the difficulties, maybe we can expect clarity by exempting for the past.

If this happens then those who have paid and availed the credit will not have a problem. However those who have notavailed credit due to technical or understanding reasons may have to go for refund.

RCM Under section 9(3) of the ACt, is still continued but RCM under section suspended till 31.03.2018.