RCM on mining royalty

The receipent is liable to discharge the tax liability on RCM @ 5%

SIR, WE HAVE A CHINA CLAY MINE IN ODISHA.  WE ARE PAYING DEAD RENT AND SURFACE RENT REGULARLY.  AFTER 2017, WE COULD NOT MINE OR SELL THE MATERIAL ALREADY ON SITE.  NOW GST HAS GIVEN A LETTER ON 30.12.2019 FOR SUBMISSION OF DATA -ROYALTY, LIABILITY ON RCM BASIS, LIABILITY PAID.  WE HAVE NOT PAID ANY ROYALTY. AS THERE IS NO SALES.  KINDLY CLARIFY.

Yes...GST is applicable on royalty paid to government for undertaking mining activity. Further it is to be noted that GST should be paid under RCM.