The Constitution (122nd Amendment) Bill, 2016, for introduction of the goods and services tax (GST) in the country was accorded assent by the President Pranab Mukherjee on September 8 and the same has been notified as the Constitution (One Hundred and First Amendment) Act, 2016 which was ratified by more than 50 per cent state assemblies.

In exercise of the powers conferred by Article 279A of the Constitution, the President hereby constituted the Goods and Services Tax Council on 16th September 2016. GST Council will work out the details of the tax, including the rate at which it will be levied.

GST will replace multiple indirect taxes levied by centre and states, creating one national market that is expected to bump up GDP by as high as 2 per cent.

Once the date of the new tax is notified all state and central taxes that it subsumes will cease to exist. The government is looking to implement the new tax regime from April 1, 2017.

The GST Council, a body of states and Centre, is constituted with Union finance minister as its chair and state finance ministers as its members. The Centre will have one-third weight in the council while states together will have the remaining two-third. Decisions will have to passed by three-fourth vote, implying the need for consensus.  Hence opinion of both centre and state will be important.

The first meeting of the GST Council was held on September 22-23.  GST Council on Friday 23-09-2016 fixed annual turnover limit for exemption at Rs 20 lakh for all states barring the north-east and hill-area states.  The GST threshold was set at Rs 10 lakh for the north-east and hill states.  Hence Exemption limit of GST is increased to double than earlier proposed in the draft GST. The said increase is in line with the majority of the people’s demand to increase the turnover limit for exemption under GST.

 It has also adopted a cross-empowerment model for tax administration, a formula for compensating states and agreed to subsume all cesses into the new tax.

At the end of the first meeting, the Council headed by Finance Minister Arun Jaitley decided that the state authorities will have jurisdiction over assessees with annual turnover of less than Rs 1.5 crore.

Those with turnover of over Rs 1.5 crore, Jaitley said there would be cross examination either by officers from the Centre or state to avoid dual control .  Therefore the same is a big relief to all businessmen as majority were worried about dual control. Now everyone will have to deal with only one authority under GST.

However, the power for assessment of 11 lakh service tax assesses who are currently assessed by Centre, would remain with it. As service tax is a central levy and the state has no experience of service industry hence they have kept power for assessment of service tax assesses who will be merged under GST with centre. But new assesses which would be added to the list would be divided between the Centre and states.

The base year for calculating compensation to the states would be 2015-16 and the formula for payment of compensation would be deliberated between the state and Central authorities. The officials will give a presentation with regard to the compensation formula which can be adopted at the next meeting of the Council on September 30.

While the next meeting of the Council on September 30 will also finalise draft rules on granting exemptions, the GST rate and tax slabs would be decided at its three-day meeting beginning October 17.

The council will take crucial decisions including the rate, laws, rules and procedures and administrative framework that will form the core of the CGST law and the IGST law, which be passed apart from the state GST laws before the tax can be rolled out.

Once the central GST law is finalised, the government would introduce it in the winter session while states would take state GST law to their assembly.

“The GST, once implemented, would have a transformational impact by creating a seamless national market in the country for the first time,” Jaitley had said.

The GST will subsume central taxes such as excise duty and service tax and state taxes including VAT, octroi, entry tax.

A committee headed by chief economic adviser Arvind Subramanian has suggested a revenue neutral rate of 15-15.5 per cent and standard rate of around 18 per cent.

Reverse Charge under Goods & Service tax Act

At present Reverse charge is there only in Service tax i.e. Service tax is payable by service provider on rendering of services but in few cases service tax is payable by recipient of services on reverse charge basis/partial reverse charge basis like on Goods Transport Agency service, Legal Service, Rent a cab service, Manpower Supply Service, Import of taxable service, Security service, Service portion in execution of works contract, sponsorship services etc

But Reverse charge is not there on Goods except in few states like Punjab where Purchase tax is there on certain Goods.  VAT is payable on sales by the seller of Goods   but the payment of VAT in the hands of the purchaser (registered dealer) on purchase of goods from an unregistered dealer.

Now under GST regime Reverse Charge will be there on both Services & Goods. Hence coverage of reverse charge will increase as Goods are also covered therefore collection of GST under reverse charge will increase tremendously. The said is also because of Make in India initiative launched by the Government of India to encourage multi-national, as well as national companies to manufacture their products in India. It was launched by Prime Minister Narendra Modi on 25 September 2014. Hence Manufacturing of Goods will increase as a result of which tax collection of GST under reverse charge on goods will also increase.

Why is Reverse charge needed?

Reverse charges is introduced by the Government normally in Un-organised sectors or partly-organised sectors for better tax coverage & better tax compliance.

Reverse charge mechanism under Goods & Service Tax Act :

Normally, the supplier of goods and / or services will be liable to discharge tax on the supplies affected. However, the Central Government is empowered to specify categories of supplies in respect of which the recipient of goods and / or services will be liable to discharge the tax. Accordingly, all other provisions of this Act and CGST Act, as applicable, will apply to the recipient of such goods and / or services, as if the recipient is the supplier of such goods and / or services i.e. for the limited purpose of such transactions, the recipient would be deemed to be the ‘supplier’.

Section 2(85) “reverse charge’’, means the liability to pay tax by the person receiving goods and / or services instead of the person supplying the goods and / or services in respect of such categories of supplies as the Central or a State Government may, on the recommendation of the Council, by notification, specify;

Section 2(34) “Council” means the Goods and Services Tax Council established under Article 279A of the Constitution;

The GST Council, a body of states and Centre, is notified on 16th September 2016 with Union finance minister as its chair and state finance ministers as its members.

7. Levy and Collection of Central/State Goods and Services Tax (CGST/SGST)

(1) There shall be levied a tax called the Central/State Goods and Services Tax (CGST/SGST) on all intra-State supplies of goods and/or services at the rate specified in the Schedule . . . to this Act and collected in such manner as may be prescribed.

(2) The CGST/SGST shall be paid by every taxable person in accordance with the provisions of this Act.

(3) Notwithstanding anything contained in sub-section (2), the Central or a State Government may, on the recommendation of the Council, by notification, specify categories of supply of goods and/or services the tax on which is payable on reverse charge basis and the tax thereon shall be paid by the person receiving such goods and/or services and all the provisions of this Act shall apply to such person as if he is the person liable for paying the tax in relation to such goods and/or services.

Hence based on above one can conclude that the levy of tax on supply of goods and / or services is in two parts –

(i)  in the hands of the supplier as per section 7(1) of CGST/SGST and

(ii) in the hands of the recipient of goods / services under reverse charge mechanism as per section 7(3) of CGST/SGST.

Specifically, in respect of the tax payable on reverse charge basis, the following conditions would be mandatory:

(a) Recommendation of the Council.

(b) Notification specifying the categories of supply of goods and / or services.

Person required to pay tax under reverse charge mechanism shall be taxable persons irrespective of the threshold / value of aggregate turnover.

Hence under reverse charge mechanism tax will be payable from rupee one except in case of personal use exemption will be available up to certain limit.

According to my opinion exemption limit should also be made available for tax payable under reverse charge basis because actually under reverse charge basis you are paying tax on behalf of person who has supplied to you Goods or Services.

Section 12. Time of supply of goods

(5) In case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earliest of the following dates, namely—

(a) the date of the receipt of goods, or

(b) the date on which the payment is made, or

(c) the date of receipt of invoice, or

(d) the date of debit in the books of accounts.

Explanation.- For the purpose of clause (b) of sub-section (5), “the date on which the payment is made” shall be the date on which the payment is entered in the books of accounts of the recipient or the date on which the payment is debited in his bank account, whichever is earlier.

(7) In case it is not possible to determine the time of supply under the provisions of subsection (2), (3), (5) or (6), the time of supply shall

(a) in a case where a periodical return has to be filed, be the date on which such return is to be filed, or

(b) in any other case, be the date on which the CGST/SGST is paid.

13. Time of supply of services

(5) In case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earliest of the following dates, namely-

(a) the date of receipt of services, or

(b) the date on which the payment is made, or

(c) the date of receipt of invoice, or

(d) the date of debit in the books of accounts

Explanation.- For the purpose of clause (b) of sub-section (5), “the date on which the payment is made” shall be the date on which the payment is entered in the books of accounts of the recipient or the date on which the payment is debited in his bank account, whichever is earlier.

(7) Where it is not possible to determine the time of supply of services in the manner specified in sub-sections (2), (3), (5) and (6), the time of supply shall (a) in a case where a periodical return has to be filed, be the date on which such return

(a) in a case where a periodical return has to be filed, be the date on which such return is to be filed; or

(b) in any other case, be the date on which the CGST/SGST is paid.

The above provisions are explained with an example as below:

Sl. NO. Date of Receipt of Service Date of receipt of Invoice Date of Making Payment Date of Debit in books of accounts Time of Supply
1 21.06.2017 22.06.2017 10.05.2017 23.06.2017 10.05.2017
2 22.06.2017 23.06.2017 28.06.2017 24.06.2017 22.06.2017
3 26.06.2017 27.06.2017 30.07.2017 25.06.2017 25.06.2017
4 26.04.2017 29.04.2017 30.07.2017 05.04.2017 05.04.2017

Hence based on above one can conclude that Time of supply of Goods and Time of Supply of services in case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis can be easily determined if we know all below dates namely,

(a) the date of the receipt of goods, or services

(b) the date on which the payment is made, or

(c) the date of receipt of invoice, or

(d) the date of debit in the books of accounts.

Further in case of (b) the date on which payment is made we should also know (b) (i) the date on which the payment is entered in the books of accounts of the recipient (b) (ii) or the date on which the payment is debited in his bank account.

If we know all above dates then Time of Supply of Goods and Time of Supply of services in case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis will be the date which is earliest date among all dates.

From above one has to also enter in the accounting software/system

(a) the date of the receipt of goods, or services.

(b) (ii) or the date on which the payment is debited in his bank account.

(c) the date of receipt of invoice.

To enter above dates one has to also modify accounting/taxation software accordingly.

Once above dates are entered then accounting/taxation software should automatically give reports of Time of Supply of Goods and Time of Supply of services in case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis for all items of Goods or Services. The real challenge will come in cases where transactions are bulky. However we can make task little easy in case of automation through system as explained above but data should be entered correctly to get correct result.

If above dates are not entered and maintained in the accounting/taxation software then it will be difficult to find out Time of Supply of Goods and Time of Supply of Services in case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis. In other words then in such scenario litigation with the department will increase.

Where services cease pre-maturely, they will be deemed to be supplied at the time of cessation.

The above situation can arise when the quality of services received are unsatisfactory or services are not received as per the contract dates,  then one can terminate the contract earlier than in that case the Time of supply of services will be then time of cessation.

Time of supply may be decided as the last-resort based date, when periodical return is due or tax is paid.

The above situation can arise when accounting/taxation system is crashed or fire has occurred and all records are destroyed.

Section 26. Furnishing details of inward supplies

(2) Every registered taxable person shall furnish, electronically, the details of inward

supplies of taxable goods and/or services, including inward supplies of services on which the tax is payable on reverse charge basis under this Act and inward supplies of goods and/or services taxable under the IGST Act, and credit or debit notes received in respect of such supplies during a tax period on or before the fifteenth day of the month succeeding the tax period in such form and manner as may be prescribed.

SCHEDULE III

LIABILITY TO BE REGISTERED

1. Every supplier shall be liable to be registered under this Act in the State from where he makes a taxable supply of goods and/or services if his aggregate turnover in a financial year exceeds [Rs nine lakh]:

2. Every supplier shall be liable to be registered under this Act in the State from where he makes a taxable supply of goods and/or services if his aggregate turnover in a financial year exceeds [Rs. four lakh]:

[This threshold of four lakh will apply only if the taxable person conducts his business in any of the NE States including Sikkim.]

Provided that the supplier shall not be liable to registration if his aggregate turnover consists of only goods and/or services which are not liable to tax under this Act.

Hence based on above one can conclude that registration has to be obtained from each state from where supplier of goods or services makes a taxable supply. Hence centralised registration scheme available under service tax act at present will not be available under GST therefore even in case of centralised accounting or centralised billing multiple registrations are required each state wise hence multiple returns are to be filed therefore compliance work will increase drastically. We are talking about ease of business now therefore according to my view centralised registration facility should be made available.

Further now, the  above limit will increase to Rs 18 lacs and Rs 9 lacs (for North-East States including Sikkim) in line with recent increase in exemption limit of turnover in recent GST council meeting of 23-09-2016.

2. Subject to the provisions of paragraph 1, every person who, on the day immediately preceding the appointed day, is registered or holds a license under an earlier law, shall be liable to be registered under this Act with effect from the appointed day.

5. Notwithstanding anything contained in paragraph 1 and 2 above, the following categories of persons shall be required to be registered under this Act:

(iii) persons who are required to pay tax under reverse charge, irrespective of the threshold specified under paragraph 1;

Hence registration under GST is compulsory for tax payable under reverse charge basis irrespective of threshold limit. Hence according to my view as receiver of goods or services is paying tax on behalf of supplier of goods or services hence threshold of exemption limit should also be made available under reverse charge basis.

The following are specifically excluded from the meaning of ‘taxable person’:

(e) Where any person is liable to pay tax on services under reverse charge mechanism, if the value of services received is less than a specified amount during the year and if the said services are received for personal use (other than in the course of or furtherance of business).

The above exemption of services received up to a specified value will be applicable only if such services are meant for personal use. Where any services are received in the course of, or furtherance of business, the threshold will not be applicable i.e.  will be liable to tax, irrespective of the threshold.

Hence tax will be payable under reverse charge even in case of personal use exceeding the specified amount during the year.

At present under service tax trough mega exemption Notification No. 25/2012-Service Tax dated 20-06-2012

the Central Government, being satisfied that it is necessary in the public interest so to do, hereby exempts the following taxable services leviable thereon under section 66B of the said Act, namely:-

14. Services by way of construction, erection, commissioning, or installation of original works pertaining to,-

(b)  a single residential unit otherwise than as a part of a residential complex;

Hence service tax is exempt on construction, erection, commissioning or installation of original works pertaining to a single residential unit irrespective of any amount.  But under GST suppose above mentioned said category of service will be notified on recommendation of GST council for reverse charge then even if the same is for personal use but if amount will exceed the specified amount then GST will be payable on reverse charge basis.

Therefore, the intention of the government appears to tax the higher middle class/rich/super rich also under GST, hence receiver of specified goods or specified services notified on recommendation of GST council for reverse charge GST even for personal use exceeding specified limit has to take registration under GST which will result into increasing GST net and accordingly GST collection will increase.

CHAPTER– III

LEVY AND COLLECTION OF TAX

4. Levy and collection of Integrated Goods and Services Tax (IGST)

(1) There shall be levied a tax called the Integrated Goods and Services Tax on all supplies of goods and/or services made in the course of inter-State trade or commerce at the rate specified in the Schedule to this Act and collected in such manner as may be prescribed.

(2) The Integrated Goods and Services Tax shall be paid by every taxable person in accordance with the provisions of this Act.

(3) Notwithstanding anything contained in sub-section (2), the Central Government may, on recommendation of the Council, by notification, specify categories of supply of goods and/or services the tax on which is payable on reverse charge basis and the tax thereon shall be paid by the person receiving such goods and/or services and all the provisions of this Act shall apply to such person as if he is the person liable for paying the tax in relation to such goods and/or services.

Above provisions are same as Section 7 (1) to (3) of CGST/SGST except in section 7(1) supply of goods or services is taxable if supply is made in intra-state for e.g. supply of goods or services are taxable if made within same state i.e.  Gujarat to Gujarat or Maharashtra to Maharashtra and under section 4 (1) of IGST supply of goods or services made in the course of inter-state trade or commerce i.e. one state to another is taxable for e.g.  Maharashtra to Gujarat or Delhi  to Haryana etc.

Similarly GST is payable on reverse charge basis under Section 7 (3) of CGST/SGST for intra-state receipt of specified notified goods or specified notified services and GST is payable on reverse charge basis under section 4(3) of IGST for receipt of specified notified goods or specified notified services in inter-state trade.

Another exception is under section 7 (3) of CGST/SGST, Central Government or State Government on recommendation of the council will notify classes of Goods or services on which GST is payable on reverse charge basis but in section 4(3) of IGST only Central Government on recommendation of the council will notify classes of goods or services on which GST is payable on reverse charge basis.

Components of valid GST Return for Outward Supplies made by the Taxpayer (GSTR-1) (vii) Details relating to supplies attracting Reverse charge will also be submitted

26. Furnishing details of inward supplies

(2) Every registered taxable person shall furnish, electronically, the details of inward supplies of taxable goods and/or services, including inward supplies of services on which the tax is payable on reverse charge basis under this Act and inward supplies of goods and/or services taxable under the IGST Act, and credit or debit notes received in respect of such supplies during a tax period on or before the fifteenth day of the month succeeding the tax period in such form and manner as may be prescribed.

The Major payments reflected in the Electronic Cash Ledger would include some of the following:

a) Tax paid on outwards supplies.

b) Interest on belated payment of tax.

c) Compounding fee paid in compounding proceedings

d) Payment by way of reverse charge etc

Section 35(3) provides that the amount reflected in the Electronic Cash Ledger may be used for payment of tax, interest, penalty, fee, or any other amount. However, the manner of utilization, condition and timelines are yet to be prescribed. It is not clear as to whether cross-utilization of balances in cash ledger in between the major/minor heads would be permitted.

In accordance with my views, excess GST paid on outwards supplies will be allowed to be set off against  GST payable on outward supplies, excess GST paid on reverse charge basis will be allowed to be set off against GST payable on reverse charge basis, excess interest on delayed payment of GST will be allowed to be set off against interest payable on delayed payment of GST. The same is because accounting codes of GST payable on outwards supplies, GST payable on reverse charge basis & Interest on GST will be different when we will pay the same. Hence if excess GST payable will be allowed to be set off with Interest payable on delayed payment of GST then Government will face reconciliation issue in its Management Information System (MIS).

Payment through Electronic Credit Ledger

(i) Input Tax Credit would be credited to the Electronic Credit Ledger. Balance in Electronic Credit Ledger can only be utilized towards making payment of tax but not for making payment of interest, fee & penalties. Here provision is very clear balance in electronic credit ledger will be allowed to be utilized only for making payment of tax but will not be allowed for making payment of interest, fee & penalties.

The Electronic Credit Ledger shall be maintained in the manner to be prescribed. The

Electronic credit ledger may include the following:

a) ITC on inward supplies from registered tax payers.

b) ITC eligible on payment made on reverse change basis etc

ITC is rightly eligible on payment made on reverse change basis as you are paying GST on behalf of someone.

The Electronic Credit Ledger has only three Major Heads of Credit:

Input Tax Output Tax
IGST IGST

CGST

SGST

CGST CGST

IGST

SGST SGST

IGST

Hence, cross utilization of credit is available only as above IN THAT ORDER. The main restriction is that the CGST credit cannot be utilized for payment of SGST and vice versa.

Other Important Points:

Only taxable persons whose ‘aggregate turnover’ does not exceed Rs. 50 lacs in a financial year will be eligible to opt for payment of tax under the composition scheme.

Section 2 (6) “aggregate turnover” means the aggregate value of all taxable and non-taxable supplies, exempt supplies and exports of goods and/or services of a person having the same PAN, to be computed on all India basis and excludes taxes, if any, charged under the CGST Act, SGST Act and the IGST Act, as the case may be;

Explanation.- Aggregate turnover does not include the value of supplies on which tax is levied on reverse charge basis and the value of inward supplies. Turnover on which Tax is payable on reverse charge basis is excluded from definition of aggregate turnover because you are paying tax under reverse charge basis on behalf of someone hence  the same cannot be rightly added into your aggregate turnover.

Composition scheme is not available for tax payable under reverse charge basis. According to my view composition scheme should be also allowed for tax payable under reverse charge basis because you are paying tax on behalf of someone, so not allowing composition scheme for reverse charge is unfair.

Government has normally introduced reverse charge basis tax in un organised sectors or partly unorganised sectors for better compliance and better tax collection hence because I am receiving such goods or services where tax is payable on reverse charge basis then at least allow me all benefit of act as if I have to pay tax on outward supply of Goods or Services.

Input tax: “Input tax” in relation to a taxable person, means the {IGST and CGST}/{IGST and SGST} charged on any supply of goods and/or services to him which are used, or are intended to be used, in the course or furtherance of his business and includes the tax payable under reverse charge. [Section 2(57)].

Section 7(3) levies tax on goods and/or services on reverse charge. Therefore, ‘input tax credit’ is the tax paid by a taxable person under the Act whether on forward charge or reverse charge for the use of such goods and/or services in course or furtherance of his business.

In both the definition reverse charge is rightly added as you are paying tax on behalf of someone hence credit for the same should be allowed to be set off.

Section 2 (72)”output tax” in relation to a taxable person, means the CGST/SGST chargeable under this Act on taxable supply of goods and/or services made by him or by his agent and excludes tax payable by him on reverse charge basis;

Section 2 (73) “outward supply” in relation to a person, shall mean supply of goods and/or services, whether by sale, transfer, barter, exchange, licence, rental, lease or disposal made or agreed to be made by such person in the course or furtherance of business except in case of such supplies where the tax is payable on reverse charge basis.

In both the definition reverse charge basis is excluded because this is not your tax, this is not your supply but you are only paying tax on receipt basis on behalf of someone.

Frequently Asked Questions (FAQ)

Q1. Is the reverse charge mechanism applicable only to services under GST?

Ans. No, in terms of Section 7(3) of CGST/SGST and Section 4(3) of the IGST, it is applicable to both Goods and Services. Hence as Goods is also included in reverse charge under GST therefore tax collection under GST will increase tremendously.

Q2. What will be the implications in case of purchase of goods from unregistered dealers?

Ans. The GST law as on date, leaves this question unanswered but the receiver of goods could be liable to pay tax under reverse charge on same basis as under VAT, purchase tax is payable in some states like State of Punjab.

Q3. Is option to pay GST under Composition scheme is applicable to tax payable under reverse charge basis.

Ans. No, the option of Composition scheme is not applicable for payment of tax payable under reverse charge basis.

Q4. The tax payable on reverse charge basis under IGST will be notified by:

(a) The State Government

(b) The Central Government on recommendation of the Council

(c) CBEC

(d) Recipient of goods and / or services

Ans: (b) The Central Government on recommendation of the Council

Q5. The tax payable on reverse charge basis under CGST/SGST Act will be notified by:

(a) The State Government

(b) The Central Government

(c) The Central Government or a State Government on recommendation of the Council

(d) CBEC

(e) Recipient of goods and / or services

Ans: (c) The Central Government or a State Government on recommendation of the Council

Q6.  Where services are performed from outside India (say) in relation to immovable property like real estate brokers or architects, how will payment of IGST apply?

Ans: In such cases, it is likely that IGST may be imposed on ‘reverse charge’ basis so that the tax is payable by the recipient of the services and not the supplier of the services. At present service tax is payable on reverse charge basis for import of services, in similar lines IGST will be payable under GST for import of such services.

(Author can be reached on cajineshgada@gmail.com)

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8 responses to “Reverse Charge under GST Law”

  1. SHIV RATAN BUDHIA says:

    IS GST APPLICABLE ON BROKERAGE OF LESS THAN 20 LAKHS FOR A FINANCIAL YEAR

  2. Ravindra says:

    As per my understanding only CGST & SGST liability create under RCM

    and there is no Liability of IGST even service / Goods procure from other state
    (except sin goods)

    am i correct..

  3. vishvanath says:

    If my retail customer(who is unregistered dealer) is giving me goods worth re 5000 and in exchange taking goods worth re 15000, i have to charge him GST on 15000/– . But do i have to pay GST on 5000/– under reverse charge mechanism ?

  4. Ritesh Amrutbhai Patel says:

    Respected Sir,

    We are service receiver not registered under GST act and our provider also not registered under GST Act so what will be the tax liability , please suggest , we both are not liable to pay GST or any other way.

  5. Dharmesh Gupta says:

    If a trader or manufacturer purchase goods from an agriculturist who is not at all registered either under vat act or gst &sells both taxable after mabnufacture or trade taxable as well as exempt list goods or zero rated goods presently exept under vat of state & his turnover is below 50lacs ,can he opt for composition scheme in gst.?

  6. KUMAR says:

    THANK YOU SIR GOOD EXAMPLES

  7. Hemal says:

    If I have more than one branch in state as well as out of the state than I have to register in different GST No, or Same No. to all branches in all over the Country including in same state ?

  8. M P Keshava says:

    Thanks for a very lucid explanation of Reverse Service Charge tax.
    Our company has a centralized payment office. So, a even when an unit in Mumbai suffers a reverse charge GST, actual payment will be made by Chennai Central Payment Office against this transaction. Does this office have to take any extra registrations under GST act?

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