RCM on Advance Payment of Commercial Property

RCM should not apply to the advance paid on 5 October 2024, if it was genuinely paid before 10 October and relates to the October rent. For a continuous supply of services, where the invoice is not issued by the supplier, the time of supply under section 13(3) of the CGST Act is generally the earlier of the date the recipient pays or the date immediately following 60 days from the supplier’s invoice. On these facts, the payment date is before the notified RCM start date.

“Effective from 10 October” means the new liability applies to supplies whose relevant time of supply falls on or after that date; it does not, by itself, make an earlier payment taxable merely because the return is filed later. The 20 November GSTR-3B due date is a reporting deadline, not the test for deciding when the supply becomes liable. Keep evidence of the advance payment and check the agreement, invoice and payment trail, as those facts can affect the time-of-supply analysis.

This date-based check is important when processing rent advances and preparing the recipient’s GST liability and return. Manual review of agreements, invoices and payment records is difficult, and automation can reduce repetitive work while keeping professional judgment in control. At Jir AI, our 2,000+ AI agents and 650+ integrations streamline GST, ITR, TDS, TCS and other compliance workflows, helping reduce manual workload by up to 70%. For a practical walkthrough tailored to your compliance workflow, connect with us on WhatsApp: https://wa.me/message/3HVOZ7HIY4ESC1