No ...as new section 9(4) Has been inserted by Amendment Act 31 of 2018 , notified by Notification 2/2019 " The Govt may , on the recommendation of council by Notification , specify the class of registered person who shall in respect of supply of specified category of goods or Services or both reced from URD , pay tax on RCM "
And only Notification 7/2019 CT (r) is notified till date , the RCM for promoter
hence No RCM is applicable
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