With India's digital economy expanding at an unprecedented pace, the Institute of Chartered Accountants of India (ICAI) has released a detailed and updated "Handbook on E-Commerce Operators under GST", offering much-needed clarity on taxation, compliance, and evolving legal provisions governing online platforms.
The handbook, issued by ICAI's GST & Indirect Taxes Committee, serves as a practical guide for Chartered Accountants, tax professionals, start-ups, e-commerce businesses, and policymakers, addressing the unique GST challenges faced by digital marketplaces, aggregators, and service platforms.
E-Commerce Under GST: Why This Handbook Matters
E-commerce has emerged as a major growth driver in India, but its multi-state operations, complex supply chains, and high transaction volumes have created significant interpretational issues under GST. Recognising this, ICAI's handbook consolidates statutory provisions, notifications, circulars, and judicial guidance into a single reference document.
The publication is updated up to 15 December 2025, incorporating recent amendments and clarifications issued by the Government.
Key Areas Covered in the Handbook
The handbook provides structured guidance on all critical aspects of GST applicable to e-commerce operators (ECOs), including:
- Definition of E-Commerce and E-Commerce Operators under Sections 2(44) and 2(45) of the CGST Act
- Business Models Explained - Marketplace, Inventory, and Aggregator models
- Special GST Provisions under Section 9(5), where tax liability is shifted from suppliers to ECOs
- Tax Collection at Source (TCS) under Section 52, including rates, valuation, returns, and matching mechanism
- GST Registration Requirements, including mandatory registration and APOB compliance
- Return Reporting in GSTR-1, GSTR-3B, GSTR-8, GSTR-9, and GSTR-9C
- Recent Notifications and Circulars, including changes effective from 2024 and 2025
Section 9(5): Deemed Supplier Concept Explained
One of the most significant areas addressed is Section 9(5) of the CGST Act, under which certain services supplied through e-commerce platforms-such as passenger transportation, accommodation, restaurant services, housekeeping, and local delivery-require the E-Commerce Operator to pay GST as a deemed supplier.
The handbook explains:
- When the ECO is liable to issue invoices and pay tax
- Cases where the supplier retains liability
- Cash-only payment of GST for Section 9(5) services
- Non-applicability of TCS on notified services
This clarity is especially relevant for platforms like ride-hailing apps, food delivery services, hotel aggregators, and home-service platforms.
Important Compliance Insights for Sellers and Platforms
The handbook also highlights key compliance risks, such as:
- Mandatory declaration of ECO-managed warehouses as Additional Place of Business (APOB)
- Consequences of incorrect place of supply determination
- Impact on Input Tax Credit (ITC) and invoice validity
- Treatment of turnover for aggregate turnover calculation, even where tax is paid by the ECO
ICAI's Commitment to GST Awareness
In the foreword, CA Charanjot Singh Nanda, President, ICAI, emphasized that the handbook reflects ICAI's commitment to ease of doing business, transparency, and capacity building in India's indirect tax ecosystem. The publication is intended to be a ready reckoner for professionals navigating GST in the digital economy.
Who Should Read This Handbook?
- Chartered Accountants & GST Practitioners
- E-commerce operators and start-ups
- Online sellers and service providers
- Finance and compliance teams
- Policy analysts and regulators
Final Word
As GST provisions for e-commerce continue to evolve, this ICAI handbook arrives at a crucial time, offering practical clarity, compliance direction, and legal certainty. For anyone dealing with GST in the digital marketplace, this publication is an indispensable resource.
Official copy of the handbook has been attached
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