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GST Returns for Real Estate

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: Verify Credentials →

Documents: Project ledger, booking schedule, RERA registration, JDA agreement, and vendor master.

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

Eligibility: Residential developers, commercial promoters, JDA landowner / developer counterparties, and RREP / REP projects.

Timeline: GSTR-1 by 11th, GSTR-3B by 20th, 80% annual true-up by 30 June, JDA RCM at the CC date.

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Real Estate GST Compliance at a Glance

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

Under the post 1 April 2019 regime, residential under-construction attracts 1% (affordable: 60 sqm metro / 90 sqm non-metro, value up to INR 45 lakh) or 5% (other) without ITC. Commercial in pure REP attracts 12% with ITC; commercial in RREP attracts 5% without ITC. 80% of project inputs (excluding land, FSI, TDR, electricity, cement) must be procured from registered persons under Notification 7/2019-CTR - shortfall attracts 18% RCM. Cement from URD attracts 28% RCM regardless. TDR / FSI on or after 1 April 2019 attracts 18% RCM capped at 1%/5% of unsold flats on CC. ITC for construction on own account is blocked under Section 17(5)(d) post the Finance Act 2025 retrospective amendment. Patron Accounting starts from INR 2,499 per month.

Real estate GST is the most rule-dense sector in the entire CGST framework. The 33rd GST Council meeting and Notifications 3/2019-CTR to 8/2019-CTR (all dated 29 March 2019, effective 1 April 2019) replaced the old 8% / 12% with-ITC regime with a 1% / 5% without-ITC regime for residential supplies, an 80% registered-procurement condition under Notification 7/2019-CTR, and a comprehensive RCM regime on TDR / FSI under Notifications 4/2019-CTR and 5/2019-CTR. Developers with ongoing projects on 31 March 2019 had a one-time option to continue under the old scheme (with ITC) by filing Annexure IV by 20 May 2019; non-filing was deemed acceptance of the new scheme.

The Section 17(5)(c) and (d) ITC-blocking provisions returned to centre stage with the Safari Retreats Supreme Court ruling in October 2024 - which allowed the functionality test to qualify buildings as plant and reopened ITC for leasing-purpose construction. The Finance Act 2025 then retrospectively replaced plant or machinery with plant and machinery with effect from 1 July 2017, nullifying the relief. The Supreme Court dismissed the review petition in May 2025, and the November 2025 AAR ruling confirmed the door is now closed. Patron Accounting LLP runs full monthly real estate GST compliance starting from INR 2,499 per month per project / GSTIN - covering rate determination, 80% tracking, JDA / TDR RCM, Section 17(5) defence, and RERA escrow alignment.

Content is reviewed quarterly for accuracy.

What Is GST Returns for Real Estate?

GST returns for real estate is the monthly compliance workflow for developers, promoters, and construction service providers under the post 1 April 2019 regime - covering rate identification (1% / 5% / 12% / 18%), Annexure IV election tracking for ongoing projects, 80% registered procurement monitoring under Notification 7/2019-CTR, JDA landowner-share GST on the completion certificate / first occupation date, TDR and FSI RCM at 18%, ITC blocking under Sections 17(5)(c) and (d) post the Finance Act 2025, RERA escrow alignment, and full monthly GSTR-1 and GSTR-3B filing.

A complete monthly close also addresses Schedule II Entry 5(b) treatment of under-construction sales as service supply, Schedule III Entry 5 and 5A exclusion of land sale and post-completion building sale from GST, Rule 42/43 ITC apportionment for promoters still under the old scheme with mixed taxable / exempt supply, and DRC-01C structural mismatch defence. The objective is zero ITC leakage on commercial projects under the old scheme, correct cash-only liability for the new scheme, and audit-ready documentation for departmental scrutiny.

Key Terms for GST Returns for Real Estate:

  • RREP (Residential Real Estate Project): A project where the carpet area of commercial apartments is not more than 15% of the total carpet area of all apartments. The commercial portion attracts 5% without ITC.
  • REP (Real Estate Project): Any project other than an RREP. Commercial apartments in a pure REP attract 12% with ITC.
  • Affordable Residential Apartment: A residential apartment with carpet area up to 60 sqm in metropolitan cities or 90 sqm in non-metropolitan cities, with gross consideration up to INR 45 lakh. Attracts 1% GST without ITC.
  • Promoter: Defined in Section 2(zk) of the RERA Act, 2016 - a person who constructs an apartment or building for the purpose of sale.
  • JDA (Joint Development Agreement): An agreement where the landowner contributes land and the developer constructs apartments. The landowner share is a supply by the developer, valued at the CC / first occupation date.
  • TDR / FSI: Transferable Development Rights / Floor Space Index - tradeable development rights. On or after 1 April 2019, transfer attracts 18% RCM with a cap at 1%/5% of unsold flats on the CC date.
APL-05 GST Returns for Real Estate
New Scheme 1% / 5%

Who Needs This Compliance

Any developer, promoter, JDA counterparty, or construction service provider in the following categories needs ongoing monthly GST support:

  • Residential developers with affordable housing projects under PMAY, CLSS, or state schemes attracting the 1% rate
  • Residential developers selling other residential apartments at 5% without ITC
  • Mixed-use developers running an RREP with up to 15% commercial carpet area at 5%
  • Commercial developers in a pure REP at 12% with ITC
  • Developers with ongoing projects on 31 March 2019 who exercised the old-scheme option (8% / 12% with ITC)
  • JDA landowners and developers - co-related GST treatment on the landowner share
  • Plotted development projects and infrastructure developers
  • Real estate investment trusts (REITs) and SPVs with construction-leasing models
  • Co-development arrangements with TDR / FSI inflows post 1 April 2019
  • Promoters facing 80% shortfall exposure at year-end true-up
  • Commercial leasing developers re-evaluating ITC post the Finance Act 2025 retrospective amendment

Statutory Deadlines

GSTR-1 by the 11th of the following month (or 13th for QRMP). GSTR-3B by the 20th (or 22nd / 24th for QRMP). 80% true-up by 30 June of the FY following the project FY (Notification 7/2019-CTR). JDA RCM on the date of CC or first occupation. TDR / FSI RCM on the date of transfer.

Patron Accounting Services

ServiceWhat We Do
Project-Level Rate DeterminationMapping each apartment / unit to the correct rate - 1% affordable, 5% other residential, 5% commercial in RREP, 12% commercial in pure REP. Definition checks for affordable, RREP / REP classification, and one-time option tracking for ongoing projects under Annexure IV.
80% Procurement Tracking under Notification 7/2019-CTRMonthly tracking of inputs and input services procurement split between registered and unregistered, excluding land, FSI, TDR, electricity, and cement. Cement separately tracked for 28% URD RCM. Annual true-up by 30 June with shortfall RCM at 18% on the gap.
JDA and TDR / FSI RCM ComplianceJDA landowner-share GST computation, time of supply at CC / first occupation date (Notification 6/2019-CTR), TDR / FSI RCM at 18% on the date of transfer, capped at 1%/5% of unsold flats on CC. Self-invoice and payment voucher under Section 31(3)(f) and (g).
Monthly GSTR-1 + GSTR-3B FilingOutward supplies in GSTR-1 by the 11th, including the project-wise apartment booking schedule. GSTR-3B by the 20th with new-scheme cash payment (no ITC utilisation under Notification 3/2019), old-scheme ITC with Rule 42/43 reversal, and RCM on JDA / TDR / cement / shortfall.
Section 17(5)(c) / (d) Post Finance Act 2025 AdvisoryImplementation of the Finance Act 2025 retrospective amendment (plant or machinery to plant and machinery, effective 1 July 2017) - revised ITC claim, a board note for past-period exposure under Section 73(5), and forward-looking defence against AAR / departmental scrutiny.
RERA Escrow + GST AlignmentSection 4(2)(l)(D) RERA 70% escrow interacts with GST cash payment under the new scheme (cash-only discharge). We align escrow withdrawals against GSTR-3B liability and document the trail for joint RERA / GST scrutiny.
Our Process

Our Process

From onboarding and project mapping through the monthly close and GSTR filing to the annual 80% true-up and JDA / TDR RCM at the CC date.

Step 1

Onboarding and Project Mapping

We collect GSTIN credentials, the project list with RERA registration numbers, JDA agreements, ongoing-project Annexure IV declarations, the vendor master, and the last 12 months of returns. Output: a project-level rate matrix in 5 to 7 days.

RERA list Rate matrix
Onboarding 01
Step 2

Monthly Close

By the 7th of each month, we pull GSTR-2B, reconcile against the project ledger, classify each booking by apartment rate, compute the 80% running ratio, identify JDA / TDR / cement RCM triggers, and prepare a close memo.

80% ratio RCM triggers
Reconcile 02
Step 3

GSTR-1 Filing

Outward supplies by the 11th with apartment-wise B2C disclosure, advance receipts, and CC-date triggered JDA outflow.

B2C apartments Advances
GSTR-1
GSTR-1 03
Step 4

GSTR-3B Filing

New-scheme cash-only liability via PMT-06; old-scheme ITC with Rule 42/43 reversal; RCM on JDA, TDR / FSI, cement URD, and the 80% shortfall. Section 49(4) cash-only restriction for RCM.

Cash-only Rule 42/43
GSTR-3B
GSTR-3B 04
Step 5

Annual 80% True-Up

By 30 June following each project FY, compute the registered vs unregistered procurement ratio (excluding land, FSI, TDR, electricity, cement). Pay 18% RCM on any shortfall via Form GST DRC-03 or include it in the next GSTR-3B.

30 June Shortfall RCM
80%
True-Up 05
Step 6

JDA / TDR RCM at CC

On the date of CC / first occupation, compute the landowner-share GST, the TDR / FSI 18% RCM with the 1%/5% cap on unsold flats, and discharge via GSTR-3B Table 3.1(d).

Landowner share Unsold cap
CC / JDA
CC Trigger 06

Document Checklist

The GST portal accepts PDF or JPEG uploads. Real estate compliance depends on accurate project, RERA, JDA, and vendor data.

  • Project list with RERA registration number, project type (residential / commercial / mixed), and launch date
  • Apartment-wise carpet area and consideration schedule for rate determination
  • Annexure IV / V / VI declarations for ongoing projects (if filed by 20 May 2019)
  • JDA agreements, area-sharing terms, and landowner counterparty GSTINs
  • TDR / FSI transfer documents, dates, and consideration
  • Vendor master with GSTIN, registration status, and procurement category (input / input service / cement)
  • Last 12 months GSTR-1, GSTR-3B, GSTR-2B for the project GSTIN
  • Past departmental correspondence (ASMT-10, DRC-01A, DRC-01) on rate, ITC, or 80%

Common Challenges and How We Resolve Them

ChallengeImpactHow Patron Accounting Solves It
80% Shortfall Identified at Year-EndNotification 7/2019-CTR requires at least 80% of inputs and input services (excluding land, FSI, TDR, electricity, cement) from registered suppliers; any shortfall attracts 18% RCM on the gap.We run monthly tracking, flag shortfall mid-FY, restructure the vendor mix where possible, and where unavoidable, compute and discharge the 18% RCM via DRC-03 or the next GSTR-3B with documentation.
ITC on Commercial Leasing Re-Blocked Post Finance Act 2025Safari Retreats (October 2024) reopened ITC under the functionality test, but the Finance Act 2025 retrospectively replaced plant or machinery with plant and machinery from 1 July 2017, nullifying the relief; the SC dismissed the review in May 2025.We compute the past-period exposure, advise on Section 73(5) voluntary disclosure to avoid penalty, and document the position for ongoing departmental defence.
JDA Landowner-Share GST Not Paid at CC DateNotification 6/2019-CTR fixes the time of supply at CC or first occupation; defaulting to invoice or booking date triggers 18% interest under Section 50.We compute the CC-date liability, file DRC-03 for past periods, and align forward CC dates with GSTR-1 / 3B reporting.
TDR / FSI RCM Cap on Unsold Flats MisappliedPer Notification 5/2019-CTR, TDR / FSI attracts 18% RCM but the tax is capped at 1% (affordable) or 5% (other) of unsold apartments on the CC date - often misapplied.We compute both the 18% gross and the capped amount and discharge the lower at the CC date, with full documentation of unsold inventory.

Patron Accounting Fees

Fee ComponentAmount
Monthly GST Returns - Single Project / GSTINStarting from INR 2,499 per month (Exl GST and Govt. Charges)
Monthly Returns + 80% Tracker + JDA RCMStarting from INR 4,999 per month (Exl GST and Govt. Charges)
Project Rate Determination + Annexure IV ReviewQuote on call - per project
JDA / TDR / FSI RCM Computation (per transaction)Quote on call - per transaction
Section 17(5) Post Finance Act 2025 AdvisoryQuote on call - per project exposure
Multi-Project / Multi-GSTIN Group ComplianceQuote on call - per project / GSTIN
Government Fees on the GST PortalNIL on filing; statutory tax and RCM 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 Real Estate consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Time Taken

StageEstimated Timeline
Onboarding (credentials, project mapping)5 to 7 days
Project rate matrix (per project)3 to 5 days
Monthly close and reconciliation7th to 12th of each month
GSTR-1 filingBy 11th (monthly) or 13th (QRMP)
GSTR-3B filingBy 20th (monthly) or 22nd / 24th (QRMP)
JDA / TDR RCM at CC dateIn return period of CC / first occupation
80% annual true-upBy 30 June following project FY
Section 17(5) past-period exposure review15 to 30 days per project
Annual GSTR-9 / 9CBy 31 December of following FY

Key deadlines: GSTR-1 by the 11th, GSTR-3B by the 20th, the 80% true-up by 30 June following the project FY, and JDA / TDR / FSI RCM in the return period of the CC or first-occupation date.

Key Benefits

Why Engage a Professional

Zero Rate Mismatch

Affordable / RREP / REP / commercial mapped per Notification 3/2019-CTR.

80% Tracker Prevents Year-End Demand

Monthly visibility on the registered procurement ratio.

JDA / TDR RCM at Correct CC Date

Eliminates Section 50 interest exposure on the landowner share.

Section 17(5) Post Finance Act 2025 Readiness

Past-period voluntary disclosure under Section 73(5).

RERA Escrow + GST Cash Alignment

Clean joint-scrutiny defence on cash-only discharge.

Lower Long-Term Cost

One INR 2,499 per month engagement saves crores in 80% RCM, JDA interest, and ITC reversal.

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 real estate developers across Pune, Mumbai, Delhi, Gurugram, Bengaluru, and Hyderabad.

Outcome proof: a Gurugram-based residential developer with three RERA projects facing a INR 1.2 crore 80% shortfall demand at year-end closed the position to nil through retrospective vendor restructuring and DRC-03 cement-specific RCM payment within our monthly tracker framework.

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 Gurugram for local coordination.

DIY vs Patron Accounting Real Estate Compliance

ParameterDIY / Internal TeamPatron Accounting Compliance
Rate determinationOften misapplied - affordable vs other confusedPer Notification 3/2019-CTR with carpet area + consideration check
80% procurementYear-end shock - no mid-FY visibilityMonthly tracker + early warning + vendor mix advisory
JDA landowner shareBooked at invoice / agreement date - interest accruesAt CC / first occupation date per Notification 6/2019-CTR
TDR / FSI capFull 18% paid - no cap appliedCapped at 1%/5% of unsold flats on the CC date
Section 17(5) post 2025Continued claim - SCN riskPast exposure addressed via Section 73(5); forward block accepted
RERA + GST alignmentEscrow vs cash payment mismatchJoint reconciliation in the monthly close
Cost (typical)Hidden - 80% shortfall, JDA interest, ITC reversalStarting from INR 2,499 per month per project / GSTIN
Audit / board comfortLowHigh - signed monthly compliance pack

Related Patron Services

Real estate 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 Refund - export refund under Rule 96 / Rule 89 and inverted duty refund under Section 54(3).
  • GST Audit - statutory and management audit including the 80% true-up and JDA review.
  • GST Notice - DRC-01C, ASMT-10, and DRC-01 representation on real estate disputes.

We also offer GST Reverse Charge Mechanism (RCM) Compliance (JDA, TDR/FSI, cement URD, and 80% shortfall RCM), GST Valuation Services (JDA landowner-share valuation under Rule 28 and Section 15), and GST Classification and HSN/SAC Advisory (SAC 9954 construction services classification and rate determination), as part of the same engagement.

Legal and Compliance Framework

Governing Act and Rules: Central Goods and Services Tax Act, 2017 read with the CGST Rules, 2017, Notifications 3/2019-CTR to 8/2019-CTR, and the RERA Act, 2016.

ElementReference
Charging sectionSection 9 CGST Act + Schedule II Entry 5(b) - construction = supply of service
Outside supply - landSchedule III Entry 5 CGST Act
Outside supply - completed buildingSchedule III Entry 5A CGST Act (inserted via Finance Act 2019)
New scheme ratesNotification 3/2019-CTR dated 29 March 2019 amending Notification 11/2017-CTR
Affordable residential1% (0.5% CGST + 0.5% SGST) without ITC - 60 sqm metro / 90 sqm non-metro, up to INR 45 lakh
Other residential5% (2.5% CGST + 2.5% SGST) without ITC
Commercial in RREP (up to 15%)5% without ITC
Commercial in pure REP12% with ITC - Notification 11/2017-CTR original
Cash-only liability under new schemeNotification 3/2019-CTR - debit electronic cash ledger only; no ITC utilisation
Ongoing projects one-time optionAnnexure IV by 20 May 2019; default = new scheme
80% procurement conditionNotification 7/2019-CTR - registered procurement minimum (excl land, FSI, TDR, electricity, cement)
Shortfall RCM rate18% on the shortfall amount
Cement URD RCM rate28%
TDR / FSI RCMNotification 5/2019-CTR - 18% under Section 9(3)
TDR / FSI cap1%/5% of value of unsold apartments on CC / first occupation date
JDA landowner share TOSNotification 6/2019-CTR - date of CC or first occupation
ITC block - works contractSection 17(5)(c) CGST Act
ITC block - construction own accountSection 17(5)(d) CGST Act
Plant and machinery exception (post Finance Act 2025)Excludes land, buildings, civil structures; retrospective 1 July 2017
Safari Retreats SC rulingCivil Appeal 2948 of 2023 - October 2024 (now nullified by Finance Act 2025)
SC review dismissalCCCGST vs Safari Retreats, 20 May 2025
Time of supply - advanceSection 13 CGST + Schedule II 5(b) - on receipt of consideration before CC
Rule 42 / 43 reversal (old scheme)CGST Rules - common ITC apportionment
RERA escrowSection 4(2)(l)(D) RERA Act, 2016 - 70% of buyer payments
Demand - non fraudSection 73 CGST - 10% penalty or INR 10,000; 3-year limit
Demand - fraudSection 74 CGST - 100% penalty; 5-year extended period
Unified demand FY 2024-25Section 74A CGST
Interest18% per annum under Section 50 CGST

Authoritative references: Notification 3/2019-CTR (New Scheme Rates), CBIC CGST circulars (80% Procurement), and the CGST Act Schedule II / III (CBIC Tax Information).

What is the GST rate on under-construction residential apartments?

Under the post 1 April 2019 regime (Notification 3/2019-CTR), residential under-construction attracts 1% (CGST 0.5% + SGST 0.5%) for affordable apartments and 5% (CGST 2.5% + SGST 2.5%) for other apartments, both without input tax credit. Affordable means carpet area up to 60 sqm in metropolitan cities or 90 sqm in non-metropolitan cities, with gross consideration up to INR 45 lakh.

What is the difference between RREP and REP?

A Residential Real Estate Project (RREP) is one where the carpet area of commercial apartments does not exceed 15% of the total carpet area of all apartments. A Real Estate Project (REP) is any other project. In an RREP, both residential and commercial portions attract the new-scheme rate (1% / 5% without ITC). In a pure REP, commercial apartments attract 12% with ITC under the original Notification 11/2017-CTR.

What is the 80% procurement rule for real estate?

Under Notification 7/2019-CTR dated 29 March 2019, a promoter must procure at least 80% of inputs and input services (excluding land, FSI, TDR, electricity, and cement) from registered suppliers in a financial year. Any shortfall attracts 18% RCM on the shortfall amount. Cement procurement from unregistered suppliers attracts 28% RCM separately regardless of the 80% threshold.

How is GST on Joint Development Agreement (JDA) computed?

Per Notification 4/2018-CTR read with Notification 6/2019-CTR, the developer pays GST on the landowner share of constructed apartments. The time of supply is the date of issue of completion certificate or first occupation, whichever is earlier. Tax rate is the applicable rate of the apartment (1% / 5% / 12%) on the value of construction service supplied to the landowner.

What is the GST treatment of TDR and FSI on or after 1 April 2019?

Per Notification 5/2019-CTR, transfer of development rights (TDR) and floor space index (FSI) on or after 1 April 2019 attracts 18% GST under reverse charge (Section 9(3)). The promoter pays the tax. The tax payable is capped at 1% (affordable) or 5% (other) of the value of unsold apartments on the date of completion certificate or first occupation.

Can a real estate developer claim ITC under Section 17(5)(c) and (d)?

Section 17(5)(c) blocks ITC on works contract services for construction of immovable property, and Section 17(5)(d) blocks ITC on goods and services received for construction on own account, except for plant and machinery. The Safari Retreats Supreme Court ruling (October 2024) allowed buildings to qualify as plant under the functionality test, but the Finance Act 2025 retrospectively replaced plant or machinery with plant and machinery with effect from 1 July 2017, nullifying the relief.

Is sale of a completed flat after completion certificate liable to GST?

No. Schedule III Entry 5A of the CGST Act (inserted via Finance Act 2019) treats sale of building after issuance of completion certificate or after first occupation, whichever is earlier, as neither supply of goods nor supply of services. GST is therefore not payable on resale or sale of fully constructed and occupied flats. Schedule III Entry 5 separately keeps sale of land outside the scope of supply.

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

Starting from INR 2,499 per month (Exclusive of GST and government charges) for single-project / single-GSTIN basic compliance. Monthly returns plus 80% tracker plus JDA RCM package starts from INR 4,999 per month. JDA / TDR / FSI RCM computation, project rate determination, multi-project compliance, and Section 17(5) past-period advisory are quoted separately based on scope.

JDA me landowner ka GST kab dena hota hai?

Notification 6/2019-CTR ke under, JDA landowner share par GST CC ya first occupation ki date par dena hota hai - jo bhi pehle ho. Agreement ki date par nahi. Bahut se developers booking date ya invoice date par pay karte hain, jo galat hai - 18% per annum interest Section 50 ke under lagta hai. CC date par discharge karne se interest exposure khatam hota hai.

Quick Answers

  • What is the GST rate on affordable housing? 1% without ITC - Notification 3/2019-CTR; 60 sqm metro / 90 sqm non-metro, up to INR 45 lakh.
  • What is the GST rate on other residential apartments? 5% without ITC under the new scheme; 12% with ITC under the ongoing old scheme.
  • What is the 80% rule? Notification 7/2019-CTR - 80% of inputs and input services from registered suppliers; shortfall RCM 18%.
  • What is the cement RCM rate? 28% on cement procured from unregistered suppliers.
  • What is the JDA landowner-share time of supply? Date of CC or first occupation - Notification 6/2019-CTR.
  • Is a post-CC flat sale taxable? No - Schedule III Entry 5A excludes it from supply.

Why Move Now on Real Estate GST

The 80% shortfall RCM, JDA CC-date interest, and TDR/FSI cap mistakes are the three largest GST exposures in Indian real estate today.

Each accrues silently and crystallises at year-end true-up, the CC date, or departmental scrutiny. The Finance Act 2025 retrospective amendment on Section 17(5)(d) has reopened ITC exposure from 1 July 2017 for commercial leasing developers who relied on Safari Retreats. Voluntary disclosure under Section 73(5) before an SCN waives penalty.

Patron Accounting starts from INR 2,499 per month - a fraction of one quarter of typical demand.

The Densest Compliance in the CGST Framework

Real estate GST sits at the densest intersection of statutory complexity - 1% / 5% / 12% rates by project type, the 80% registered procurement rule, JDA landowner share at the CC date, TDR / FSI 18% RCM with the unsold-flat cap, Section 17(5)(c) and (d) ITC blocking post the Finance Act 2025 retrospective amendment, and RERA 70% escrow alignment.

Every one of these is materially monetary and audit-active. Patron Accounting LLP, with CA and CS professionals practising for 15+ years across Pune, Mumbai, Delhi, and Gurugram, runs end-to-end real estate GST compliance - from project rate determination through the monthly close, the 80% tracker, JDA / TDR RCM, Section 17(5) advisory, and RERA-aligned reconciliation - starting from INR 2,499 per month per project / GSTIN.

Pair it with core GST Returns, export GST Refund, a periodic GST Audit, and expert GST Notice representation.

Book a Free Consultation - No Obligation.

Real Estate GST Support Across India

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

Real Estate GST Returns Support by City
Monthly rate determination, 80% tracking and JDA / TDR RCM, 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 GST Council decision on real estate rates, an amendment to Notification 3/2019 or 7/2019, a new CBIC circular on JDA / TDR / FSI, an AAR/GSTAT/High Court ruling on Section 17(5)(c)/(d), or a RERA amendment to escrow norms.