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Microlesson · 5-min read

Schedule III – Activities Treated as Neither Supply of Goods nor Services (Penal/Liquidated Charges Focus)

# Schedule III – 'Non-supplies' (and CBIC Clarifications on Penal Charges)

Certain receipts that look like consideration are actually not a supply, hence no GST. Recent circulars have brought several penalty / compensation items into this list.

## A. Charges/penalties that are NOT supplies (no GST)

1. Penal charges levied by Regulated Entities (banks/NBFCs) on borrowers for non-compliance with loan terms — No GST.

2. Cheque dishonour fine / penalty charged by the supplier from a defaulting customer — Not taxable.

3. Penalty for violation of law (e.g. fines under statute) — Not taxable.

4. Forfeiture of salary / surety / bond amount by employer for breach of employment terms — Not taxable.

5. Late payment surcharge by utilities (electricity boards, telecom) — Not taxable as a separate supply. (When part of the price of the underlying supply, it follows the principal supply.)

6. Fixed/Capacity charges for power — Not taxable (electricity is exempt; capacity charges form part of the consideration for electricity, which is exempt).

7. Cancellation charges retained by the supplier when no service was rendered — generally not taxable; treated as compensation, not consideration.

## B. Liquidated Damages — A Three-Way Test

The treatment of liquidated damages depends on why they are paid:

SituationGST Treatment
Payment to make good a loss caused by the other party (true compensation)Not taxable — no supply at all
Damages paid for performing/forming a contract (e.g. demurrage, retention amounts that are part of the contract consideration)Exempt (or follows the rate of the principal supply, as applicable)
Damages arising under a separate independent contract to tolerate an act / refrain from an actTaxable as supply of service (Schedule II, para 5(e))

Memory hook: Liquidated damages that are just compensation for breach = not taxable. But if there is an independent agreement to tolerate something, that is a separate taxable service.

Worked example

### Example 1

Q. ABC Bank charges its borrower ₹5,000 as penal interest for delayed EMI payment. Is GST leviable?\nA. No. Penal charges levied by a regulated entity for borrower's non-compliance are not consideration for any supply — No GST.

### Example 2

Q. A customer cancels a hotel booking and the hotel forfeits ₹2,000 of the advance. GST?\nA. When no service has been rendered, the forfeited amount is treated as compensation, not consideration for a supply — Not taxable.

### Example 3

Q. A construction contractor pays ₹10 lakh as liquidated damages to the project owner for delay in completing the project. GST?\nA. The amount is compensation for a breach of the main contract, not a consideration for a separate agreement to tolerate the delay — Not a supply, hence not taxable.

⚠️ Common exam mistakes

  • Treating every penalty/forfeiture as 'tolerating an act' under Schedule II and charging GST on it — CBIC has clarified that compensation for breach is not a supply.
  • Charging GST on the late payment surcharge of electricity bills — capacity / surcharge in electricity bills follows the exempt supply of electricity.
  • Missing the distinction between damages under the original contract (no GST) and a separate agreement to tolerate / refrain (taxable).
Bare-Act text Schedule III · CGST Act, 2017 read with CBIC Circular No. 178/10/2022-GST dated 03.08.2022 and Circular No. 214/8/2024-GST dated 26.06.2024 · click to expand
Schedule III to CGST Act, 2017 lists activities or transactions which shall be treated neither as a supply of goods nor a supply of services — including services by an employee to the employer in the course of his employment, services by any court or Tribunal, sale of land and (subject to Schedule II, paragraph 5(b)) sale of building, actionable claims other than specified actionable claims, etc.
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