Finance/Compliance Consultant
75675 Points
Posted on 06 November 2026
Check first whether RCM applied at all. Very likely it didn't:
• RCM on purchases from unregistered suppliers (Sec 9(4)) applies since 1 February 2019 only to notified real-estate promoters (Notf 07/2019-CT(R)). Repair labour plus material from an unregistered (URD) supplier to an ordinary business is not covered, and repair services are not on the Sec 9(3) list (Notf 13/2017-CT(R)).
• So no RCM was payable in August 2024. Nothing to pay or claim.
• Only if it is a notified RCM service (GTA, legal, security by a non-body-corporate supplier, commercial rent from an unregistered landlord from 10 October 2024, sponsorship, director services, etc.) do you need to:
– pay through GSTR-3B Table 3.1(d) in the current period, with interest at 18% (Sec 50) from the original due date to payment (Rule 88B: on the cash portion)
– claim ITC in Table 4A(3) in the same return.
• ITC time limit: ITC on RCM is tied to the date of payment of RCM tax (Sec 16(4) read with Circular 211/5/2024). So late payment does not lose the ITC.