What is the 80 percent URD threshold for builders?

Per Notification 7/2019-Central Tax (Rate), a promoter must procure at least 80 percent of the value of inputs and input services (excluding development rights, TDR / FSI, land, electricity, high-speed diesel, motor spirit, natural gas) from registered suppliers. Where the unregistered share exceeds 20 percent, the promoter pays 18 percent GST on the shortfall under reverse charge. This computation is project-wise per FY and discharged in the March return.

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GST Returns for Builders and Real Estate Promoters

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Documents: Project RERA registration, sales register, landowner agreement, vendor master, URD ledger, and cement purchase log.

Fees: Starting from INR 2,499 per month (Exl GST and Govt. Charges) per project or GSTIN.

Eligibility: Real estate developers, promoters, RERA-registered builders, JV partners, and turnkey contractors.

Timeline: GSTR-1 by 11th, GSTR-3B by 20th, 80% URD shortfall RCM in March return, JDA liability at CC date.

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Builder GST Compliance at a Glance

📌 TL;DR - GST Returns for Builders and Real Estate Promoters Services at a Glance

Notification 3/2019-CTR effective 1 April 2019: RREP affordable 1% / RREP other residential 5% / RREP commercial 5% - all no ITC. REP (non-RREP) affordable 1.5% effective / other residential 7.5% effective / commercial 12% with ITC. Annexure IV old-regime option filed by 10 May 2019 (irrevocable). 80% URD threshold (Notification 7/2019-CT(R)) - shortfall = 18% RCM in March return. Cement from URD = 28% RCM always. JDA landowner share - GST at CC date. TDR / FSI = 18% RCM capped to unsold-unit GST. Patron Accounting starts from INR 2,499 per month.

Builder GST has run on a single dominant framework since 1 April 2019 - Notification 3/2019-CTR (with associated notifications 4 to 8 of 2019) brought in the without-ITC regime: 1% on affordable residential apartments, 5% on other residential, and 5% on commercial within a Residential Real Estate Project (RREP), all without input tax credit. REP (Real Estate Project) where commercial carpet area exceeds 15% of total has higher headline rates (1.5%/7.5% effective for residential after 1/3 land deduction; 12% with ITC for commercial). Annexure IV gave ongoing projects a one-time option to continue under the old 8%/12% with-ITC regime - filed irrevocably by 10 May 2019.

The compliance core sits in three rule-precise zones: the 80% URD threshold under Notification 7/2019-CT(R), which mandates that at least 80% of inputs and input services be procured from registered suppliers, with shortfall taxed at 18% RCM on a project-and-FY basis settled in the March return; cement from unregistered persons - always at 28% RCM regardless of the 80% threshold; and capital goods from URD at 18% RCM. Add JDA landowner-share liability crystallising at the Completion Certificate date (Notification 6/2019-CT(R)) and TDR / FSI 18% RCM capped at GST on unsold units (Notification 5/2019-CT(R)), and the builder regime becomes a per-project monthly plus annual close. Patron Accounting LLP runs end-to-end builder GST compliance starting from INR 2,499 per month per project or GSTIN.

Content is reviewed quarterly for accuracy.

What Is GST Returns for Builders and Real Estate Promoters?

GST returns for builders and real estate promoters is the monthly plus annual compliance workflow for developers under the post-1 April 2019 regime, covering classification of each project as RREP or REP (commercial carpet area test), apartment-wise rate selection (affordable 1% / 1.5% effective vs other 5% / 7.5% effective vs commercial 5% / 12%), the Annexure IV ongoing-project carve-out (old regime opt-in irrevocably filed by 10 May 2019), 80% URD procurement threshold tracking with annual March-return RCM computation, cement 28% URD RCM, capital goods 18% URD RCM, JDA landowner-share liability at the Completion Certificate date, TDR / FSI 18% RCM with unsold-unit cap, the 1/3 land deduction, and full monthly GSTR-1 / GSTR-3B filing.

A complete builder close also addresses Schedule II Entry 5(b) (construction of a complex or building before issuance of completion certificate is a supply) versus Schedule III Entry 5 (sale of land outside GST) and Entry 5A (sale of building after CC outside GST, inserted 1 February 2019), Section 17(5)(c) / (d) post the Finance Act 2025 retrospective amendment (which nullifies the Safari Retreats Supreme Court ruling of October 2024), RERA Section 4(2)(l)(D) 70% escrow alignment with GST liability, and DRC-01C departmental defence within the statutory window. The objective is project-wise rate-correct invoicing, URD threshold compliance, and an audit-ready RCM trail across the construction lifecycle.

Key Terms for GST Returns for Builders and Real Estate Promoters:

Promoter: A person who constructs apartments for sale (the RERA definition adopted by GST). Includes builders, developers, owner-builders, and landowners using their land for development under a JDA or JV.
Real Estate Project (REP): Any project where commercial carpet area exceeds 15% of total carpet area. The commercial portion is taxed at 12% with ITC; the residential portion at the applicable new-regime rate without ITC.
Residential Real Estate Project (RREP): Any project where commercial carpet area is up to 15% of total carpet area. All apartments (residential and commercial) are taxed at the applicable new-regime rate without ITC.
Affordable Residential Apartment: Carpet area up to 60 sqm in metropolitan areas or 90 sqm in other areas; AND gross consideration up to INR 45 lakh; AND intended for residential use as declared to RERA or the competent authority.
80% URD Threshold: Notification 7/2019-CT(R) - a promoter must procure at least 80% of the value of inputs and input services from registered suppliers; shortfall triggers 18% RCM on the deficit, computed per project per FY and discharged in the March return.
Annexure IV: A one-time declaration under Notification 3/2019-CTR for ongoing projects - opt to continue under the old 8%/12% with-ITC regime; filed by 10 May 2019; irrevocable.

URD Threshold 80%

Who Needs This Compliance

Any builder, promoter, or developer with the following compliance footprint needs ongoing monthly plus annual GST support:

RERA-registered residential builders developing RREP or REP projects
Commercial or mixed-use developers with REP classification (commercial over 15%)
Affordable housing developers under PMAY, Awas Yojana, or independent schemes
Multi-project promoters needing project-wise rate election and URD tracking
Joint Development Agreement (JDA) partners - landowners and developers
Promoters with ongoing projects under the Annexure IV old-regime option (still in delivery)
New project promoters (commenced on or after 1 April 2019) - mandatorily new regime
TDR / FSI procuring developers needing RCM cap calculation
Promoters with significant cement purchase from URD vendors
Builders facing DRC-01C / ASMT-10 on URD threshold breach or RREP / REP reclassification
Slum redevelopment, SRA, rehabilitation, and government-scheme developers

Statutory Deadlines

GSTR-1 by the 11th of the following month. GSTR-3B by the 20th. The 80% URD shortfall RCM is computed per project per FY in the March return. Annual GSTR-9 by 31 December. JDA landowner-share GST liability arises at the Completion Certificate date. TDR / FSI 18% RCM (capped) on the date of receipt. Cement from URD is discharged in the same return as the purchase.

Patron Accounting Services

Service	What We Do
Project-Wise RREP / REP Classification and Rate Election	Per-project commercial carpet area test (15% threshold); affordable test (60/90 sqm + INR 45 lakh) per residential apartment; documented rate matrix per project; Annexure IV historical compliance; new-regime confirmation for fresh projects, with a decision memo per project cross-referenced to RERA registration.
80% URD Threshold Tracking	Monthly tagging of every inward invoice as registered or unregistered (excluding statutorily excluded items); project-wise FY-to-date URD ratio tracking; March-return RCM computation on shortfall at 18%; documented trail for departmental review.
Cement and Capital Goods URD RCM	Identification of all cement purchases - if from unregistered, 28% RCM regardless of the 80% threshold; capital goods from URD at 18% RCM; reported in GSTR-3B Table 3.1(d); cash payment under Section 49(4) without ITC offset.
JDA Liability Crystallisation at CC Date	Per Notification 6/2019-CT(R), GST on the landowner share crystallises at the Completion Certificate date or first occupation, whichever is earlier. We diary the CC milestone, compute GST on the landowner share, raise the tax invoice, and settle it in the relevant month's GSTR-3B.
TDR / FSI RCM with Unsold-Unit Cap	Per Notification 5/2019-CT(R), TDR / FSI received from a landowner is taxed at 18% under RCM, capped to the GST payable on units remaining unsold at the CC date. We compute the cap, discharge cash RCM, and document the cap working for departmental defence.
Monthly Filing plus DRC-01C Defence	Monthly rate-wise GSTR-1 (1% / 5% / 12% / 1.5% / 7.5%); GSTR-3B with output tax plus RCM (URD shortfall, cement, capital goods, TDR/FSI, JDA, GTA, legal); March-return reconciliation; DRC-01C / ASMT-10 reply within the 7-day window; Section 73(5) voluntary disclosure where past-period gaps are detected.

Our Process

From onboarding and project classification through monthly close to the March-return URD computation and year-end GSTR-9.

Step 1

Onboarding

We collect GSTIN credentials, RERA registration certificates for all projects, project commencement and completion dates, the sales register, the landowner agreement or JDA, the vendor master, the cement and capital goods purchase log, the last 12 months of returns, and any pending notices. Output: a project-wise classification memo in 7 to 10 working days.

RERA certs 12-mo returns

Onboarding 01

Step 2

Project Structure Setup

RREP vs REP classification per project (commercial carpet area test); the affordable test per apartment within the project; Annexure IV verification for ongoing projects; new-regime confirmation for fresh projects. Output: a documented rate matrix per project.

Carpet test Rate matrix

Classify 02

Step 3

Monthly Close

By the 7th of each month, pull GSTR-2B; tag inward invoices as registered or unregistered (excluding statutorily excluded items); identify cement and capital goods URD; track the FY-to-date URD ratio per project. Output: a monthly close memo.

Pull 2B URD ratio

Reconcile 03

Step 4

GSTR-1 Filing

Outward supplies by the 11th with rate-wise tables - 1% affordable, 5% other residential or commercial in RREP, 1.5%/7.5% in REP, 12% commercial in REP - with project-wise B2B / B2CL / B2CS tagging and an HSN summary in Table 12.

Rate-wise By 11th

GSTR-1 04

Step 5

GSTR-3B Filing

By the 20th with output tax in Table 3.1(a); RCM in Table 3.1(d) (cement, capital goods, GTA, legal, TDR/FSI as applicable); ITC in Table 4(A) - NIL or restricted under the new regime; cash payment under Section 49(4) for all RCM.

RCM 3.1(d) By 20th

GSTR-3B 05

Step 6

March Return plus Year-End

The 80% URD threshold annual computation per project; shortfall RCM at 18% discharged in the March return; CC-date JDA reconciliation if applicable; annual GSTR-9 by 31 December with project-wise disclosure.

80% URD GSTR-9

Year-End 06

Document Checklist

The GST portal accepts PDF or JPEG uploads. Builder compliance depends on accurate project-wise carpet area and vendor registration data.

GSTIN credentials (all State registrations of the promoter)
RERA registration certificate for each project
Project commencement date evidence (approval or first agreement)
Completion certificate (or expected CC date) per project
Total and commercial carpet area calculation (for the RREP vs REP test)
Apartment-wise carpet area and consideration register (for the affordable test)
Sales register with B2B / B2CL / B2CS tagging
Landowner agreement / JDA / development rights agreement
Vendor master with GSTIN, registration status, supply category, and cement / non-cement tag
Past 12 months GSTR-1, GSTR-3B, GSTR-2B
Annexure IV historical filing acknowledgment (for ongoing projects)
Any prior ASMT-10, DRC-01A, or notice on URD threshold / RREP-REP / cement RCM

Common Challenges and How We Resolve Them

Challenge	Impact	How Patron Accounting Solves It
80% URD Threshold Breached	Where the project falls below 80% registered procurement, the shortfall is taxed at 18% RCM in the March return - often discovered too late, with interest and penalty on under-computation.	We track the FY-to-date URD ratio monthly per project, flag projected breaches by Q3, restructure procurement above 80% where feasible, and compute the shortfall RCM precisely for the March return.
Cement From URD Without 28% RCM	Cement from an unregistered supplier triggers 28% RCM always - a separate, additional obligation that many promoters miss, thinking the 80% rule subsumes it.	We identify cement-specific URD purchases monthly, compute 28% RCM in the same return, discharge in cash, and document with a vendor declaration; past gaps are rectified via Section 73(5) voluntary disclosure with interest.
RREP / REP Misclassification	The 15% commercial carpet area line determines whether the commercial portion is 5% no-ITC (RREP) or 12% with ITC (REP); a wrong call invites a department demand.	We document the carpet area calculation precisely from RERA filings, defend the RREP claim with measurement detail, and where genuinely REP, structure the commercial portion to capture full ITC at 12%.
JDA Landowner Share Missed at CC Date	Notification 6/2019-CT(R) crystallises GST on the landowner share at the CC date; many promoters discharge developer-share GST monthly but forget the landowner-share bunching, which the department picks up via RERA CC cross-reference.	We diary CC milestones per project, compute landowner-share GST at the applicable new-regime rate, raise a tax invoice, and settle it in the CC-month GSTR-3B.

Patron Accounting Fees

Fee Component	Amount
Monthly GST Returns - Single Project / GSTIN	Starting from INR 2,499 per month (Exl GST and Govt. Charges)
Monthly Returns + URD Tracking + JDA + TDR Setup	Starting from INR 5,999 per month (Exl GST and Govt. Charges)
RREP / REP Classification + Rate Election Memo	Quote on call - per project
Multi-Project / Multi-State Developer Compliance	Quote on call - per project / GSTIN
JDA / TDR / FSI Structuring Memo	Quote on call - per arrangement
DRC-01C / ASMT-10 Reply on URD / RREP / Cement	Quote on call - within the 7-day window
Government Fees on the GST Portal	NIL on filing; statutory RCM and tax are paid on actuals

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free GST Returns for Builders and Real Estate Promoters consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Time Taken

Stage	Estimated Timeline
Onboarding (credentials, project mapping)	7 to 10 days
RREP / REP classification per project	7 to 14 days
Monthly close and reconciliation	7th to 12th of each month
GSTR-1 filing	By 11th (monthly) or 13th (QRMP)
GSTR-3B filing	By 20th (monthly) or 22nd / 24th (QRMP)
80% URD threshold annual computation	In the March return of each FY
JDA CC-date landowner-share settlement	In the month of CC issuance
Annual GSTR-9	By 31 December of the following FY

Key deadlines: GSTR-1 by the 11th, GSTR-3B by the 20th, the 80% URD shortfall RCM in the March return per project per FY, the JDA landowner-share liability at the Completion Certificate date, and annual GSTR-9 by 31 December.

Key Benefits

Why Engage a Professional

Rate-Correct From Day 1

Project-wise RREP / REP and affordable / other classification.

URD Tracked Monthly

No surprise March-return RCM on the 80% threshold.

Cement and CapGoods RCM

28% cement and 18% capital goods RCM captured separately, independent of the 80% rule.

JDA Settled at CC Date

No scrutiny exposure after the RERA completion notification.

TDR / FSI Cap Computed

18% RCM with the unsold-unit cap calculated correctly.

Lower Long-Term Cost

One INR 2,499 per month engagement avoids the typical URD or cement RCM demand on a single audited project.

Trusted by Businesses Across India

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years of CA / CS Practice

Trusted by Hyundai, Asian Paints, Bridgestone, and a growing portfolio of RERA-registered builders, real estate promoters, JDA developers, and affordable housing developers across Pune, Mumbai, Delhi, and Gurugram.

Outcome proof: a Mumbai-based promoter with three concurrent RREP projects and INR 4.8 crore quarterly URD vendor exposure reduced March-return shortfall RCM from INR 64 lakh to INR 12 lakh by restructuring four major vendor contracts to registered suppliers (steel, electrical, plumbing) and tightening cement procurement to registered dealers only - all under our Q2 URD threshold projection workflow.

With offices in Pune, Mumbai, Delhi and Gurugram, Patron Accounting serves businesses across India both in-person and remotely. See our GST returns support in Mumbai for local coordination.

DIY vs Patron Accounting Builder Compliance

Parameter	DIY / Internal Team	Patron Accounting Compliance
RREP / REP classification	Project-wise carpet test sometimes skipped	Per-project documented memo from RERA filings
80% URD threshold	Often discovered at year-end - large RCM hit	Monthly tracker + Q3 projection + restructure
Cement URD RCM 28%	Confused with the 80% rule - missed	Separate monthly tagging + cash discharge
JDA landowner share at CC	Often missed - departmental detection via RERA	CC-milestone calendar + tax invoice
TDR / FSI cap calculation	Capped to the wrong base or not capped	Unsold-unit GST cap computed precisely
Annexure IV historical filing	Lost or misplaced for ongoing projects	Filed acknowledgment retrieved and applied
Cost (typical)	Hidden - shortfall RCM, cement RCM, JDA demand	Starting from INR 2,499 per month
Audit / board comfort	Low	High - signed monthly compliance pack

Related Patron Services

Builder compliance connects with other GST workstreams. Patron also handles:

GST Services - the complete GST services hub covering registration, returns, ITC, refunds, notices and audits.
GST Returns - core monthly GSTR-1 / GSTR-3B compliance for non-real-estate flows.
GST Audit - statutory and management audit including URD threshold and JDA review.
GST Notice - ASMT-10, DRC-01A, and DRC-01 representation on RREP / REP and URD threshold.

We also offer GST Returns for Real Estate (broader stakeholders - lessors, society / RWA, commercial leasing), GST Reverse Charge Mechanism (RCM) Compliance (TDR / FSI, GTA, legal, director, security, import-of-services RCM), GST Valuation Services (1/3 land deduction, JDA landowner-share valuation), and GST Classification and HSN/SAC Advisory (Heading 9954 construction classification) as part of the same engagement.

Legal and Compliance Framework

Governing Act and Rules: Central Goods and Services Tax Act, 2017 and Integrated Goods and Services Tax Act, 2017, read with the CGST Rules, 2017 and the rate notifications under Heading 9954 (Construction).

Element	Reference
Charging section	Section 9 CGST + Section 5 IGST Act
Rate notification - services	Notification 11/2017-CTR Heading 9954 (Construction)
New builder regime - 1 April 2019	Notification 3/2019-CT(R) dated 29 March 2019
Amendment notifications	Notifications 4 to 8 of 2019-CT(R)
1/3 land deduction	Paragraph 2 of Notification 11/2017-CTR
RREP definition	Notification 3/2019-CTR - commercial carpet area up to 15%
REP definition	Notification 3/2019-CTR - commercial carpet area over 15%
Affordable definition	60 sqm metro / 90 sqm non-metro + INR 45 lakh consideration
Ongoing project carve-out	Annexure IV - filed by 10 May 2019; irrevocable
80% URD threshold	Notification 7/2019-CT(R) - shortfall 18% RCM in March return
Cement URD RCM	28% always - Notification 7/2019-CT(R) read with 24/2019-CT(R)
Capital goods URD RCM	18% under Notification 7/2019-CT(R)
JDA landowner share	Notification 6/2019-CT(R) - GST at CC date or first occupation
TDR / FSI	Notification 5/2019-CT(R) - 18% RCM capped to GST on unsold units at CC
Construction is supply	Schedule II Entry 5(b) CGST - construction before CC
Sale of land	Schedule III Entry 5 CGST - outside GST
Sale of building after CC	Schedule III Entry 5A CGST - inserted 1 February 2019
Promoter definition	RERA Act adopted via GST notifications
ITC eligibility - new regime	NIL (without ITC); 80% URD condition for rate; cement separately
Construction blocked credit	Section 17(5)(c) and (d) CGST - post Finance Act 2025 amendment
Finance Act 2025 amendment	Plant or machinery to plant and machinery - retrospective from 1 July 2017
Safari Retreats SC October 2024	Overruled by the Finance Act 2025 amendment
RERA escrow	Section 4(2)(l)(D) - 70% of buyer payments in a separate account
Demand - non fraud	Section 73 CGST - 10% penalty or INR 10,000; 3-year limit
Demand - fraud	Section 74 CGST - 100% penalty; 5-year extended period
Refund time limit	Section 54(1) - 2 years from the relevant date

Authoritative references: CBIC CGST rate notifications (3/2019 and 7/2019-CT(R)) and the CGST Act and Rules (CBIC Tax Information), with the statutory base in India Code (CGST Act, 2017).

What GST rate applies to builders under the new regime?

Under Notification 3/2019-Central Tax (Rate) effective 1 April 2019, RREP projects attract 1% on affordable residential apartments, 5% on other residential, and 5% on commercial apartments - all without input tax credit. REP projects (where commercial carpet area exceeds 15%) attract 1.5% effective on affordable residential, 7.5% effective on other residential (both no ITC, after 1/3 land deduction), and 12% with ITC on commercial. Ongoing projects had a one-time option via Annexure IV to continue at old 8%/12% with-ITC rates.

What is the difference between RREP and REP?

A Residential Real Estate Project (RREP) is one where the carpet area of commercial apartments is up to 15% of the total carpet area of the project. A Real Estate Project (REP) is one where commercial carpet area exceeds 15%. In RREP, all apartments (residential and commercial) follow the new-regime rates without ITC. In REP, commercial apartments attract 12% with full ITC while residential follows the new-regime rates without ITC. The 15% line determines the rate structure for the commercial portion.

What is the 80% URD threshold for builders?

Per Notification 7/2019-Central Tax (Rate), a promoter must procure at least 80% of the value of inputs and input services (excluding development rights, TDR / FSI, land, electricity, high-speed diesel, motor spirit, and natural gas) from registered suppliers. Where the unregistered share exceeds 20%, the promoter pays 18% GST on the shortfall under reverse charge mechanism. This computation is done project-wise per financial year and discharged in the March return of that FY.

How is cement from an unregistered supplier taxed?

Cement procured from an unregistered supplier always attracts 28% GST under reverse charge, regardless of whether the 80% threshold is met. This is a separate and additional obligation from the 80% URD rule. The 28% RCM is discharged by the promoter in cash under Section 49(4) in the same return as the purchase. No ITC is available under the new regime.

What is the affordable residential apartment definition?

An apartment qualifies as affordable residential if the carpet area is up to 60 sqm in metropolitan areas (Bengaluru, Chennai, Delhi NCR, Hyderabad, Kolkata, Mumbai-MMR), or up to 90 sqm in non-metropolitan areas, AND the gross amount charged for the apartment (including parking, preferential location, etc.) does not exceed INR 45 lakh, AND the apartment is intended for residential use as declared to RERA or the competent authority. All three conditions must be met.

When does GST on JDA landowner share crystallise?

Under Notification 6/2019-Central Tax (Rate), the GST liability on transfer of development rights or FSI by a landowner to the promoter, and the corresponding GST on construction services supplied by the promoter to the landowner in a Joint Development Agreement, both crystallise on the date of issuance of the Completion Certificate or the date of first occupation of the project, whichever is earlier. Until then, the liability is deferred.

How is TDR or FSI taxed for builders?

Under Notification 5/2019-Central Tax (Rate), Transfer of Development Rights (TDR) or Floor Space Index (FSI) supplied to a promoter is taxed at 18% under reverse charge. The liability is capped at the GST that would be payable on the apartments remaining unsold at the date of issuance of the Completion Certificate. The promoter computes the cap, discharges the RCM in the relevant month, and documents the unsold-unit reconciliation.

What is the cost of monthly GST returns for builders at Patron Accounting?

Starting from INR 2,499 per month (Exclusive of GST and government charges) for single-project / single-GSTIN promoter compliance. Monthly returns plus URD tracking plus JDA plus TDR setup package starts from INR 5,999 per month. RREP / REP classification, multi-project compliance, JDA / TDR structuring memos, and DRC-01C reply are quoted separately based on scope.

Builder ka 80% URD threshold kaise track karna hai?

Promoter ko har project me FY-to-date URD ratio track karna hai. Total inputs aur input services ke value me se 80% registered suppliers se aana chahiye (development rights, TDR/FSI, land, electricity, HSD, motor spirit, natural gas chhod ke). Agar shortfall hai, toh 18% RCM lagega shortfall amount par - aur ye March return me discharge karna hai. Cement alag rule - URD cement par 28% RCM hamesha lagega, 80% rule se independent. Monthly tracking essential hai surprise avoid karne ke liye.

Quick Answers

RREP affordable rate? 1% without ITC under Notification 3/2019-CT(R).
RREP other residential rate? 5% without ITC.
REP commercial rate? 12% with full ITC.
80% URD breach consequence? 18% RCM on the shortfall in the March return.
Cement from URD? 28% RCM always (separate from the 80% rule).
JDA landowner-share GST when? At the Completion Certificate date or first occupation, whichever earlier.
TDR / FSI cap? 18% RCM capped to GST on unsold units at the CC date.

Why Move Now on Builder GST

The 80% URD threshold breaches surface as large March-return RCM demands that crystallise once the FY closes - and the year-end departmental reconciliation through RERA project completion notifications catches missed JDA landowner-share GST liabilities at the CC date.

Cement URD purchases continue to invite 28% RCM month after month while many promoters confuse this with the 80% rule. Voluntary disclosure under Section 73(5) before an SCN waives penalty, and the Finance Act 2025 retrospective amendment has closed the Safari Retreats route to ITC on construction.

Patron Accounting starts from INR 2,499 per month per project - a fraction of the typical URD threshold or cement RCM demand on a single audited project.

A Project-and-FY-Precise Compliance Regime

Builder GST is a project-and-FY-precise compliance regime - Notification 3/2019-CTR sets rates (1% / 5% RREP, 1.5% / 7.5% / 12% REP, all but commercial-REP without ITC), Notification 5/2019-CT(R) routes TDR / FSI through 18% RCM with an unsold-unit cap, Notification 6/2019-CT(R) crystallises the JDA landowner-share at the CC date, and Notification 7/2019-CT(R) demands 80% URD procurement with 18% shortfall RCM in the March return (with cement URD always at 28% RCM).

Add Annexure IV for ongoing projects, the Schedule II Entry 5(b) and Schedule III Entry 5/5A scope tests, RERA Section 4(2)(l)(D) 70% escrow alignment, and the Finance Act 2025 Section 17(5)(c)/(d) retrospective amendment closing Safari Retreats, and builder compliance becomes a full-stack discipline.

Patron Accounting LLP, with CA and CS professionals practising for 15+ years across Pune, Mumbai, Delhi, and Gurugram, runs end-to-end builder GST compliance starting from INR 2,499 per month per project / GSTIN. Pair it with core GST Returns, a periodic GST Audit, and expert GST Notice representation.

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Builder GST Support Across India

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves RERA-registered builders and promoters across India - both in-person and remotely.

Builder GST Returns Support by City

Monthly RREP/REP compliance, 80% URD tracking and JDA settlement, on-the-ground and remote

Related Services

End-to-end support across the GST compliance stack

Content Created: 27 May 2026 | Last Updated: | Next Review: 1 September 2026 | Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed quarterly (Tier 1 cadence) and on any amendment to Notifications 3 to 8 of 2019-CT(R), a GST Council rate change on construction, a new CBIC circular on the 80% URD threshold or RREP/REP classification, or further Finance Act amendments to Section 17(5)(c)/(d).

AY 2026-27 ITR filing is live - get your taxes filed accurately by CAs. CA-Assisted ITR Filing Open →