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Microlesson · 5-min read

RCM — Goods Transport Agency (GTA)

# RCM on Goods Transport Agency (GTA) Services

## Coverage

Transportation of goods by road by a GTA, where the GTA has NOT opted for Forward Charge, supplied to any of:

  • Any registered person under GST
  • Any factory
  • Any co-operative society
  • Any body corporate, partnership firm or AOP
  • Any Casual Taxable Person (CTP)

→ Recipient pays tax under RCM.

## Key definitions and rules

  • GTA = a goods transporter who issues a consignment note. A transporter who only carries goods without issuing a consignment note is not a GTA.
  • Recipient (for GTA purposes) = the person liable to pay freight.

## Exemption first, RCM later — when GTA is exempt, no RCM question

GTA service is exempt (so RCM doesn't arise) if supplied to:

  • Government department/establishment that has registered only for TDS u/s 51
  • Local authority
  • Government agency
  • Unregistered individual or unregistered casual taxable person

GTA service is also exempt if transporting any of:

  • Relief material for victims of disaster/calamity/accident
  • Defence or military equipment
  • Registered newspaper or magazine
  • Agricultural produce
  • Milk, salt or food grain (incl. flour, pulse, rice)
  • Organic manure

## Rate matrix

GTA's choiceRateITC for GTA?
Opted for FCM18% (with ITC) OR 5% (without ITC)Depends on rate chosen
Did not opt for FCM → RCM applies5% (without ITC)No ITC to GTA

ITC restriction at 5% is on the GTA only — the recipient can take full ITC of the 5% RCM tax paid.

## Two critical defaults

1. If the GTA is unregistered, assume it has not opted for FCM → RCM applies at 5%.

2. If the question is silent on FCM, assume RCM applies.

## Decision flow

```

1. Is the transporter a GTA (issues consignment note)? NO → not GTA service, normal rules.

2. Is the service / recipient covered by an exemption? YES → Exempt; stop.

3. Has the GTA opted for FCM? YES → FCM, GTA pays.

4. NO (or silent / unregistered) → RCM @ 5%, recipient pays.

```

Worked example

### Example 1

Q. XYZ Ltd. takes goods transport services from ABC Transporter, who charges tax @ 12%. Who pays GST?

A. A 12% rate indicates ABC has opted for FCM. ABC charges on the invoice and pays under FCM. XYZ takes full ITC.

### Example 2

Q. XYZ Ltd. uses ABC Transporter who has not opted for FCM. Who pays?

A. RCM applies. XYZ Ltd. (registered recipient) pays tax @ 5% directly to the Government and can take full ITC of this 5%.

### Example 3

Q. XYZ Ltd. uses ABC Transporter to transport milk, and ABC has not opted for FCM. Tax treatment?

A. Transport of milk by GTA is exempt under the exempted-goods list — therefore RCM does not arise. No tax payable by anyone.

⚠️ Common exam mistakes

  • Treating every road transporter as a GTA — only one who issues a consignment note is a GTA.
  • Applying RCM even when the recipient is an unregistered individual — GTA service to such persons is exempt.
  • Assuming the recipient cannot take ITC of 5% RCM tax — the without-ITC restriction is on the GTA, not on the recipient.
  • Forgetting the default rule: unregistered GTA / silent question → RCM at 5%.
  • Ignoring the freight-payer rule — RCM lands on whoever pays the freight, which is not always the consignor.
Reference: — Notification No. 13/2017-CT(R) (RCM notification); Notification No. 12/2017-CT(R) (exemption notification)
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