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Microlesson · 5-min read

RCM on GTA Services – Section 9(3)

# RCM on Goods Transport Agency (GTA) Services

## Notification Reference

Notification No. 13/2017 – Central Tax (Rate) dated 28.06.2017 (as amended).

## Service Covered

Services by a GTA in respect of transportation of goods by road.

## Specified Recipients (who pay under RCM)

GST is payable by the recipient under RCM when the recipient is one of the following persons located in the taxable territory:

#Specified Recipient
(a)Any factory registered under or governed by the Factories Act, 1948
(b)Any society registered under the Societies Registration Act, 1860 or under any other law
(c)Any cooperative society established by or under any law
(d)Any person registered under CGST/IGST/SGST/UTGST
(e)Any body corporate established by or under any law
(f)Any partnership firm (registered or not), including AOP — LLP is treated as a partnership firm
(g)Any casual taxable person

## RCM Does NOT Apply When Recipient is...

  • Department/establishment of CG/SG/UT, local authority, or Governmental agency, that is registered only for TDS u/s 51 and not for making taxable supply.

## When GTA Opts for Forward Charge

The RCM entry does NOT apply if the GTA has:

1. Registered and exercised the option to pay tax under forward charge, AND

2. Issued a tax invoice charging GST and made the prescribed declaration on the invoice.

## Important Points

  • Recipient of GTA services: Person liable to pay freight for transporting goods by road in a goods carriage, located in the taxable territory.
  • LLP is deemed a partnership firm under the LLP Act, 2008 — hence covered as specified recipient.

## Rate Matrix — Who Pays What?

### When Recipient IS a Specified Recipient

ScenarioRateMechanismWho Pays
GTA opts for forward charge @ 12%12%Forward ChargeGTA
GTA opts for forward charge @ 5%5%Forward ChargeGTA
GTA does NOT opt for forward charge5%Reverse ChargeRecipient

### When Recipient is NOT a Specified Recipient

(e.g., unregistered individual end consumer, unregistered casual taxable person)

GST is EXEMPT on such GTA service.

Worked example

### Example 1

Example 1 (RCM): A GTA which has not opted for forward charge transports goods at ₹50,000 freight for a registered manufacturer (a body corporate). Manufacturer pays GST @ 5% under RCM. ITC of this 5% paid in cash is available to the manufacturer.

### Example 2

Example 2 (Forward Charge @ 12%): A GTA has opted to pay under forward charge @ 12% and issues an invoice to ABC Pvt Ltd charging 12% GST. ABC pays freight + 12% GST to the GTA; no RCM applies. ABC can claim full ITC.

### Example 3

Example 3 (Exempt): A GTA (not opting for forward charge) transports household goods of an unregistered individual moving cities. The freight is exempt — no GST is payable by anyone.

### Example 4

Example 4 (Govt registered only for TDS): A GTA transports goods for a Government department registered only under Section 51 for TDS. Even though the dept is 'registered', RCM does not apply on this transaction.

⚠️ Common exam mistakes

  • Applying RCM when the GTA has opted for forward charge and issued a tax invoice with the required declaration.
  • Treating an unregistered individual recipient as triggering RCM — the unregistered individual is NOT a specified recipient; the supply is exempt.
  • Forgetting that LLPs are treated as partnership firms for this notification.
  • Charging GST under RCM where recipient is a Government dept registered only for TDS u/s 51.
  • Confusing 12% (forward charge with full ITC) with 5% (forward charge / RCM with restricted ITC for supplier).
Reference: Entry 1, issued u/s 9(3) of CGST Act — Notification No. 13/2017-Central Tax (Rate) dated 28.06.2017 (as amended)
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