Launch offer — 25% off with code LAUNCH-25 See plans →
Microlesson · 5-min read

Section 9(5) - Tax Payable by Electronic Commerce Operator (ECO)

# Section 9(5): Services Where ECO Pays GST

## Core Concept

Normally, the supplier of a service pays GST. However, Section 9(5) carves out specific services where the Electronic Commerce Operator (ECO) — through whose platform the service is supplied — is deemed to be the supplier and is liable to pay GST. All provisions of the Act apply to the ECO as if it were the supplier.

## Notified Services Under Section 9(5)

#ServiceException (ECO NOT liable)
aPassenger transport by radio-taxi, motorcab, maxicab, motorcycle, or any motor vehicle (except omnibus)
bPassenger transport by omnibusWhen supplier is a company
cAccommodation services in hotels, inns, guest houses, clubs, campsitesWhen supplier is liable for registration u/s 22(1)
dHouse-keeping services (plumbing, carpentering, etc.)When supplier is liable for registration u/s 22(1)
eRestaurant servicesRestaurant in 'specified premises' (hotel accommodation with declared tariff > ₹7,500/unit/day)

## Compliance Mechanics

  • ECO pays GST by furnishing details in Form GSTR-3B as outward supplies.
  • For Section 9(5) restaurant services, ECO does NOT:
  • Collect TCS
  • File Form GSTR-8
  • Take a separate registration for tax on restaurant services

## Key Clarifications on Restaurant Services

1. ECO must pay GST on all restaurant services routed through it — including supplies by unregistered persons.

2. Restaurant turnover is added to the supplier's aggregate turnover, NOT the ECO's.

3. Such services are not inward supplies of the ECO (so no RCM on the ECO side).

4. No proportionate ITC reversal required by the ECO for its own platform/intermediary inputs. BUT: the entire GST liability on 9(5) restaurant services must be discharged in CASH — ITC cannot be used against this.

5. ECO must raise the invoice for restaurant services supplied through it.

6. When an order contains both restaurant service AND other goods/services, ECO raises a separate bill for restaurant service; the supplier of other goods/services bills those separately.

## Who Actually Pays Tax (Location-Based Rules)

ECO LocationPerson Liable
In taxable territory (TT)ECO itself
No physical presence in TT, but has a representativePerson representing the ECO
Neither presence nor representativePerson appointed by ECO to pay tax

## Supplies Through ECO NOT Notified Under 9(5)

  • GST is paid by the actual supplier
  • ECO deposits TCS u/s 52

Worked example

### Example 1

Example 1 (Restaurant via ECO): Zomato (ECO) delivers food worth ₹1,000 from 'Hot Spot Foods' (unregistered) located in a normal commercial complex. As restaurant service is notified u/s 9(5) and the restaurant is NOT in specified premises (no hotel accommodation > ₹7,500/day), Zomato pays GST @ 5%, in CASH only (no ITC utilisation allowed for this liability). The ₹1,000 is included in Hot Spot's aggregate turnover, not Zomato's.

### Example 2

Example 2 (Hotel in specified premises): Restaurant 'The Leela Pavilion' is located inside The Leela Hotel where tariff is ₹15,000/day. Orders booked through Swiggy. Since this is a 'specified premises' restaurant, Section 9(5) does NOT apply. The restaurant itself pays GST and Swiggy only collects TCS u/s 52.

### Example 3

Example 3 (Omnibus by company vs individual): RedBus aggregates bus services. (a) Mr. X (individual) supplies omnibus via RedBus → RedBus pays GST u/s 9(5). (b) ABC Travels Pvt. Ltd. supplies omnibus via RedBus → being a company, Section 9(5) exception applies; ABC Travels pays GST.

⚠️ Common exam mistakes

  • Allowing ECO to discharge Section 9(5) restaurant service liability using ITC — it must be paid in CASH only.
  • Adding restaurant service value to the ECO's aggregate turnover instead of the supplier's.
  • Treating Section 9(5) restaurant services as inward supplies of the ECO, attracting RCM (they are NOT).
  • Forgetting the 'specified premises' carve-out — restaurants inside hotels with tariff > ₹7,500/day are outside 9(5).
  • Asking ECO to take a separate registration to pay tax on 9(5) restaurant services — not required.
  • Confusing omnibus rules: if supplier is a company, ECO is NOT liable; for any other motor vehicle, no such exception.
Bare-Act text Section 9(5) · CGST Act, 2017 · click to expand
Section 9(5) of CGST Act: The Government may, on the recommendations of the Council, by notification, specify categories of services the tax on intra-State supplies of which shall be paid by the electronic commerce operator if such services are supplied through it, and all the provisions of this Act shall apply to such electronic commerce operator as if he is the supplier liable for paying the tax in relation to the supply of such services.
Now that you've read this — what's next?
Move from understanding → mastery in 3 clicks. Each option below picks up from this lesson's topic.
Start 15-min diagnostic