Finance/Compliance Consultant
75646 Points
Posted on 06 November 2026
No RCM on MCA filing fees or additional (late) fees:
• Fees for filing forms, registration and similar statutory compliance are paid to the Central Government for regulatory services. Notf 12/2017-CT(R), Sl. 47 exempts services by the Government "by way of registration required under any law for the time being in force" and related regulatory services. CBIC FAQs on Government services treat fees for statutory filings and permissions as exempt (Sl. 6 and 47 read together).
• Since the service is exempt, the RCM entry for government services (Notf 13/2017-CT(R), Sl. 5) does not apply.
• The same goes for ROC late fees: additional fee is a statutory levy for delayed compliance, not consideration for a taxable service.
• Distinguish:
– fees paid to a CA/CS or filing intermediary for preparing forms: forward charge, 18%
– MCA's "name reservation" (RUN) and similar charges: also statutory fees, exempt.
• Accounting: debit ROC fees (Rates & Taxes / Legal & Professional – Government fees). Additional fees are compensatory, generally deductible for income-tax.