Trusted by 10,000+ Businesses

GST Reverse Charge Mechanism (RCM) Compliance

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

Documents: Vendor master, expense ledger, contracts, supplier GSTIN status, and import invoices.

Fees: Starting from INR 4,999 (Exl GST and Govt. Charges) for advisory; full setup quote on call.

Eligibility: Factories, body corporates, partnership firms, real estate developers, SaaS importers, and professional services hirers.

Timeline: RCM diagnostic in 3 to 5 working days; full compliance framework in 2 weeks.

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years

Call +91 945 945 6700 Email Us WhatsApp Us

15+ YearsIndustry Experience

CA & CSCertified Experts

4.9

Based on 500+ reviews

Get Free Consultation

Talk to a CA/CS expert today

Full Name

Phone Number

City

Service Needed

Our team will get back to you shortly. No spam.

Real Stories from Real People

Hear how teams across industries use Patron to save time, cut costs, & stay in control.

I've had an outstanding experience working with my CA - Patron Accounting. Their professionalism, attention to detail, and timely communication made the entire process seamless and stress-free.

I'm glad that I was able to connect with Patron. They took the minimum time to do the calculations based on the details provided by me and were really helpful throughout the process.

Really a fantastic experience with Patron Accounting especially Shubham, he was extremely great. Knowledgeable person who deserves the 5 star for smooth handling of all documentation.

Patron Accounting gives the best service related to all account handling of our firm. I am blessed and extremely happy that Patron Accounting assigned us a dedicated point of contact.

I have called Patron to file ITR for my 5 family members. I worked with Shubham Junjunwala and Amin Jain. It was a smooth process. They understand basics very well and respond promptly.

From the very beginning, their approach has been highly professional, prompt, and solution-oriented. Every interaction reflected their deep knowledge and commitment to helping clients.

Very proficient and professional staff. Do fantastic job and instant response. Strongly recommended engaging them for all accounting needs specially for startups and growing businesses.

I contacted them to file the ITR. Shubham was the POC for me and he was really very professional and giving prompt responses. Highly recommend them for tax and compliance work.

Sunny Ashpal

Director - Demandify Media

Anjanay Srivastava

Founder - Hunarsource Consulting

10,000+Businesses ServedGST compliance and litigation support across India.

15+Years ExperienceDeep expertise in IP registration, GST & business compliance.

50,000+Documents FiledReturns, appeals, and filings handled accurately.

4.9★Client RatingTrusted by entrepreneurs, startups, and growing businesses.

ISO CertifiedProfessional standards and documented processes.

SSL SecureYour financial and business data is fully protected.

RCM Compliance at a Glance

📌 TL;DR - GST Reverse Charge Mechanism (RCM) Compliance Services at a Glance

RCM is GST paid by the recipient instead of the supplier under three triggers - Section 9(3) notified services (GTA, legal, director, sponsorship, import etc.), Section 9(4) URD purchases (now mostly the real estate 80% rule), and Section 9(5) ECO. Registration is mandatory under Section 24(iii) regardless of threshold. Self-invoice within 30 days under Rule 47A (effective 1 November 2024). Pay in cash via PMT-06; claim ITC the same period under Rule 36(1)(b). Time of supply for services = earlier of payment date or the 61st day from the supplier invoice (Section 13(3)). Patron Accounting RCM advisory starts from INR 4,999.

Reverse Charge Mechanism (RCM) is the GST regime where the recipient, not the supplier, pays the tax. The law covers three distinct triggers under the CGST Act, 2017: Section 9(3) covers notified goods and services (Notification 4/2017-CT(R) for goods, Notification 13/2017-CT(R) for services); Section 9(4) covers specified purchases from unregistered suppliers (largely restricted post 1 February 2019, with real estate developers as the major affected class under Notification 7/2019-CT(R)); Section 9(5) covers e-commerce operator (ECO) deemed-supplier scenarios. Sections 5(3), 5(4), and 5(5) of the IGST Act mirror these provisions for inter-state and import-of-service supplies.

RCM is one of the highest-frequency audit findings under statutory and departmental GST audits. The post-November 2024 self-invoicing deadline of 30 days under Rule 47A, the amended time-of-supply test under Section 13(3), and the Circular 211/5/2024-GST clarification on ITC time limits have made RCM compliance a continuous discipline - not a year-end exercise. Patron Accounting LLP delivers an RCM diagnostic, a notified-services mapping for your expense ledger, self-invoice and payment voucher templates, and monthly GSTR-3B Table 3.1(d) reconciliation - starting from INR 4,999 for advisory.

Content is reviewed quarterly for accuracy.

What Is GST Reverse Charge Mechanism Compliance?

GST Reverse Charge Mechanism (RCM) compliance is the end-to-end discipline of identifying inward supplies that attract reverse charge under Section 9 of the CGST Act or Section 5 of the IGST Act, paying GST in cash through the electronic cash ledger, issuing self-invoices and payment vouchers as required, and claiming corresponding input tax credit (ITC) under Rule 36(1)(b) of the CGST Rules.

A compliant RCM workflow covers vendor classification (registered / unregistered / foreign), notified services mapping, GSTR-3B Table 3.1(d) liability reporting, ITC claim under Table 4(A)(3), and audit-ready documentation including the 30-day Rule 47A self-invoice, the Section 31(3)(g) payment voucher, and a vendor-wise reconciliation. RCM is mandatory and the recipient cannot opt out, even if the supplier offers to discharge the tax under forward charge (except for GTAs who validly opt under Annexure V).

Key Terms for GST Reverse Charge Mechanism (RCM) Compliance:

Reverse Charge: Section 2(98) CGST - the liability to pay GST is on the recipient instead of the supplier under Section 9(3), 9(4), or 9(5) CGST.
Section 9(3) RCM: Notified goods and services where RCM applies regardless of supplier status. Service list in Notification 13/2017-CT(R); goods list in Notification 4/2017-CT(R).
Section 9(4) RCM: Supplies from unregistered suppliers to specified registered classes - now mainly real estate developers under Notification 7/2019-CT(R).
Section 9(5) RCM: E-commerce operators deemed as suppliers for notified categories like food delivery, hotel, and passenger transport.
Self-Invoice: Invoice issued by the recipient under Section 31(3)(f) when supply is from an unregistered supplier - must be issued within 30 days under Rule 47A.
Payment Voucher: Document issued by the recipient under Section 31(3)(g) at the time of making payment to the supplier for an RCM supply.

Sec 9(3) RCM

Who Needs RCM Compliance Support

RCM applies broadly across business types. The following common scenarios trigger RCM obligations:

Any registered person hiring a Goods Transport Agency (GTA) by road that has not opted for 12% forward charge under Annexure V
Any business entity (other than a non-business entity) availing legal services from an individual advocate, senior advocate, or firm of advocates
Any registered company paying sitting fees, commission, or consultancy to a non-executive director under Notification 13/2017 entry 6
Any registered person receiving sponsorship services from an individual or firm
Any registered person availing import of services from a foreign supplier (Notification 10/2017-IT(R))
Real estate developers / promoters not meeting the 80% registered procurement threshold under Notification 7/2019-CT(R) - shortfall of cement, capital goods, or other inputs from URD attracts RCM
Any business engaging insurance agents, recovery agents (for banks / NBFCs), or direct selling agents (DSAs)
Banks and NBFCs receiving services from RBI committee members, business correspondents, or SEBI-notified lenders
Any registered person availing renting of immovable property by Central / State Government
E-commerce operators in notified categories like passenger transport (Uber, Ola), food delivery (Swiggy, Zomato), hotel accommodation by unregistered, and housekeeping

Statutory Registration

Section 24(iii) of the CGST Act mandates registration for any person liable to pay tax under RCM, regardless of the aggregate turnover threshold. The INR 20 / 40 lakh threshold does not apply.

Patron Accounting Services

Service	What We Do
RCM Diagnostic and Notified Services Mapping	A 360 review of the expense ledger and vendor master to identify every transaction triggering Section 9(3), 9(4), or 9(5) RCM. Output is a vendor-wise RCM matrix with applicable rates, notification reference, and ITC eligibility.
Self-Invoice and Payment Voucher Framework	Setup of compliant self-invoice templates (Section 31(3)(f) read with the Rule 47A 30-day rule) and payment voucher templates (Section 31(3)(g)). Integration with the accounting ERP for automated generation on URD or import-of-service entries.
Real Estate 80% Rule Compliance (Section 9(4))	For real estate developers and promoters: monthly tracking of the registered vs unregistered procurement ratio under Notification 7/2019-CT(R), computation of cement-specific 100% URD RCM, and a year-end true-up of the 80% threshold.
Monthly GSTR-3B Table 3.1(d) and 4(A)(3) Reconciliation	RCM liability reporting in Table 3.1(d) and corresponding ITC claim in Table 4(A)(3) of GSTR-3B, with PMT-06 payment and self-invoice cross-referencing.
Import of Services Advisory	Treatment of foreign affiliate fees, SaaS subscriptions from non-taxable territory, software licenses, royalties, and management fees under Section 5(3) IGST + Notification 10/2017-IT(R). Place of supply mapping under Section 13 IGST.
Departmental Representation on RCM Notices	Reply to ASMT-10, DRC-01A, and DRC-01 SCN on RCM non-payment or short-payment, including the Circular 211/5/2024-GST defence on ITC time limits for past-year self-invoices.

Our Process

From the scoping call and ledger pull through notified-services mapping, time-of-supply determination, and self-invoice build to GSTR-3B reconciliation and audit-ready documentation.

Step 1

Scoping Call and Ledger Pull

We collect the expense ledger, the vendor master with GSTIN status, the last 12 months purchase register, and any past ASMT-10 / DRC-01A correspondence. Free 15 to 30 minute consultation.

Expense ledger Vendor master

Scoping 01

Step 2

Notified Services Mapping

We map each vendor and expense line to Section 9(3) (Notification 13/2017-CT(R) and 10/2017-IT(R)), Section 9(4) (Notification 7/2019-CT(R) for real estate), or Section 9(5) (Notification 17/2017-CT(R) for ECOs).

9(3)/(4)/(5) RCM matrix

Mapping 02

Step 3

Time of Supply Determination

For services, the earlier of payment date or the 61st day from the supplier invoice under Section 13(3) (amended via Finance Act 2024). For goods, the earliest of receipt, payment, or the 31st day from invoice under Section 12(3).

61st day rule Goods 31 days

Time of Supply 03

Step 4

Self-Invoice and Payment Voucher Build

Rule 47A 30-day self-invoice (effective 1 November 2024 per Notification 20/2024-CT) for URD supplies; payment voucher under Section 31(3)(g) for all RCM supplies on payment.

30-day self-invoice 31(3)(g) voucher

Self-Invoice 04

Step 5

GSTR-3B Reconciliation

RCM liability in Table 3.1(d); ITC claim in Table 4(A)(3) subject to Section 16 and Rule 36(1)(b) conditions. ITC time limit per Circular 211/5/2024-GST is the FY of self-invoice issue.

Table 3.1(d) ITC 4(A)(3)

GSTR-3B 05

Step 6

Audit-Ready Documentation

Vendor reconciliation, self-invoice register, payment voucher trail, GSTR-3B working papers, and notification references. Optional handover to the internal team or ongoing managed compliance.

Self-invoice register Working papers

Documentation 06

Document Checklist

RCM compliance depends on accurate vendor, expense, and contract data. The following documents support the diagnostic and ongoing compliance:

Vendor master with GSTIN, registration status, and PAN
Last 12 months expense ledger and purchase register
Sample invoices for GTA, legal, director, sponsorship, and import-of-service expenses
Director appointment letters and sitting fee resolutions (for Section 9(3) entry 6)
Real estate project ledger with cement and capital goods purchase split (for the Section 9(4) 80% rule)
Foreign vendor agreements and FIRC / payment records (for import of services)
Past GSTR-3B filings showing RCM declared in Table 3.1(d) and ITC in Table 4(A)(3)
Any departmental correspondence (ASMT-10, DRC-01A, DRC-01) on RCM

Common Challenges and How We Resolve Them

Challenge	Impact	How Patron Accounting Solves It
GTA Charging 12% Forward Charge - Is RCM Still Applicable?	Confusion over whether RCM applies when a GTA bills 12% can lead to double payment or missed ITC.	No - under Notification 5/2022-CT(R) read with Notification 22/2017-CT(R), a GTA that opts for 12% forward charge via Annexure V is liable as supplier; the recipient simply claims ITC. We verify the GTA Annexure V status before applying RCM.
Director Sitting Fees vs Salary - Which Attracts RCM?	Misclassifying executive-director salary as RCM, or missing RCM on non-executive sitting fees, both create exposure.	Sitting fees, commission, and consultancy to a non-executive / independent director attract RCM under entry 6 of Notification 13/2017-CT(R) and Circular 140/10/2020-GST; salary under an employer-employee relationship is outside GST under Schedule III. We map each payment to the correct head.
Real Estate Developer Missed the 80% Threshold	Falling below 80% registered procurement triggers 18% RCM on the shortfall, with cement from URD at 28% regardless.	We compute the shortfall, file the RCM liability, and structure future procurement to stay above 80% under Notification 7/2019-CT(R).
Department Denying RCM ITC Because Self-Invoice Was Raised Late	Late self-invoices risk ITC denial on the underlying-supply FY basis.	Circular 211/5/2024-GST clarified that the relevant FY for the Section 16(4) limit is the FY of self-invoice issuance; we use this to defend ITC on backdated self-invoices, subject to interest on the delayed liability and possible Section 122 penalty.

Patron Accounting Fees

Fee Component	Amount
RCM Diagnostic (single entity, up to 50 vendors)	Starting from INR 4,999 (Exl GST and Govt. Charges)
Self-Invoice + Payment Voucher Framework Setup	Starting from INR 4,999 (Exl GST and Govt. Charges)
Monthly Managed RCM Compliance (per GSTIN)	Quote on call - varies by vendor count and complexity
Real Estate 80% Rule Compliance (per project)	Quote on call - varies by project size
Import of Services RCM Advisory (per agreement)	Quote on call - varies by foreign vendor count
Departmental Representation (Sections 73 / 74 / 74A)	Quote on call - varies by demand quantum
Government Fees	NIL for advisory; apply only if a departmental filing is required

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 Reverse Charge Mechanism (RCM) Compliance consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Time Taken

Stage	Estimated Timeline
RCM diagnostic (single entity)	3 to 5 working days
Self-invoice and payment voucher framework setup	5 to 10 working days
Real estate 80% rule monthly compliance	5 working days per month
Import of services RCM advisory (per agreement)	5 to 10 working days
Reply to ASMT-10 / DRC-01A on RCM	7 to 14 working days
Section 73 / 74 / 74A SCN reply	15 to 30 working days (within statutory limit)

Key deadlines: the Rule 47A 30-day self-invoice from receipt of supply, RCM time of supply (the earlier of payment or the 61st day for services), cash-only RCM payment via PMT-06, and the ITC claim in the same GSTR-3B subject to Circular 211/5/2024-GST.

Key Benefits

Why Engage a Professional

Audit-Grade RCM Register

Eliminates the single most frequent finding in statutory and departmental GST audits.

Rule 47A Compliance

The 30-day self-invoice deadline (effective 1 November 2024) operationalised across all URD vendors.

ITC Recovery on Past Self-Invoices

Defended using the Circular 211/5/2024-GST clarification on the Section 16(4) time limit.

Real Estate 80% Rule Tracker

Prevents year-end RCM surprises and cement-specific exposures.

Lower Long-Term Cost

One INR 4,999 advisory engagement can save lakhs in interest and penalty on cumulative RCM shortfalls.

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 SMEs across manufacturing, real estate, SaaS, professional services, and import-heavy businesses.

Outcome proof: a Gurugram-based real estate developer with INR 220 crore annual cement and capital-goods procurement closed a Section 9(4) audit query at zero additional demand using our monthly 80% tracker plus cement-specific RCM register - replacing a piecemeal year-end exercise that had previously triggered a INR 84 lakh shortfall.

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 RCM Compliance

Parameter	DIY / Internal Team	Patron Accounting Compliance
Vendor mapping	Manual, ledger-by-ledger; gaps common	Notified-services matrix; full Section 9(3)/(4)/(5) coverage
Self-invoice Rule 47A 30 days	Often missed for URD supplies	Templates and ERP triggers in place
Time of supply post Finance Act 2024	Frequently uses the old 60-day rule	Correctly applies the 61st day under Section 13(3)
Real estate 80% tracker	Year-end only - leads to spikes	Monthly tracking + cement-specific register
Director sitting fees treatment	Often missed or misclassified as salary	Mapped per Circular 140/10/2020-GST
ITC recovery on past self-invoices	Often forfeited	Defended using Circular 211/5/2024-GST
Cost (typical)	Hidden - interest, penalty, lost ITC	Starting from INR 4,999 per advisory
Audit / board comfort	Low	High - signed CA register and review

Related Patron Services

RCM 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 - monthly GSTR-1 / GSTR-3B filing with RCM liability and ITC reflected correctly.
GST Audit - statutory and management audit with RCM as a primary check area.
GST Notice - ASMT-10, DRC-01A, and DRC-01 representation on RCM disputes.
GST Annual Returns - GSTR-9 / GSTR-9C reconciliation with RCM disclosures.

We also offer GST Place of Supply Determination (place of supply for import of services drives Section 5(3) IGST RCM), GST Valuation Services (valuation under Section 15 read with Rule 28 for related-party imports under RCM), and GST Classification and HSN/SAC Advisory (HSN / SAC for self-invoice line items and rate determination), as part of the same engagement.

Legal and Compliance Framework

Governing Act and Rules: Central Goods and Services Tax Act, 2017 and IGST Act, 2017 read with the CGST Rules, 2017, the relevant CBIC notifications and circulars.

Element	Reference
Definition - Reverse Charge	Section 2(98) CGST Act, 2017
Notified services RCM (CGST)	Section 9(3) CGST + Notification 13/2017-CT(R) dated 28 June 2017
Notified services RCM (IGST)	Section 5(3) IGST + Notification 10/2017-IT(R) dated 28 June 2017
Notified goods RCM	Section 9(3) CGST + Notification 4/2017-CT(R) dated 28 June 2017
URD purchases RCM (restricted)	Section 9(4) CGST + Notification 7/2019-CT(R) dated 29 March 2019 (real estate)
ECO deemed supplier	Section 9(5) CGST + Notification 17/2017-CT(R) dated 28 June 2017
Self-invoice	Section 31(3)(f) CGST Act
Self-invoice time limit	Rule 47A CGST Rules (Notification 20/2024-CT dated 8 October 2024; effective 1 November 2024) - 30 days from receipt
Payment voucher	Section 31(3)(g) CGST Act - at time of payment to supplier
Time of supply - goods	Section 12(3) CGST - earliest of receipt, payment, or 31st day from invoice
Time of supply - services	Section 13(3) CGST - earlier of payment date or 61st day from invoice (amended via Finance (No. 2) Act 2024)
ITC documentation	Rule 36(1)(b) CGST Rules - self-invoice + payment voucher
ITC time limit	Section 16(4) CGST + Circular 211/5/2024-GST dated 26 June 2024 - FY of self-invoice issue
Compulsory registration	Section 24(iii) CGST - no threshold for RCM-liable persons
GTA forward charge option	Notification 22/2017-CT(R); 5/2022-CT(R) - 12% with full ITC by filing Annexure V
Director services RCM	Notification 13/2017 entry 6; Circular 140/10/2020-GST
Cash payment for RCM	Section 49(4) CGST - ITC cannot be used to discharge RCM liability
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
Unified demand (FY 2024-25 onwards)	Section 74A CGST
Interest on shortfall	18% per annum under Section 50 CGST

Authoritative references: Notification 13/2017-CT(R) (Notified Services RCM), Circular 211/5/2024-GST (RCM ITC Time Limit), and the CGST Act 2017 (CBIC Tax Information).

What is Reverse Charge Mechanism (RCM) under GST?

Reverse Charge Mechanism is the GST regime where the recipient of a supply, not the supplier, is liable to pay GST. RCM applies under three triggers: Section 9(3) CGST for notified goods and services (GTA, legal, director, sponsorship and others), Section 9(4) for specified purchases from unregistered suppliers (largely real estate post 1 February 2019), and Section 9(5) for e-commerce operator deemed-supplier scenarios.

Which services are covered under Section 9(3) RCM?

Notification 13/2017-CT(R) lists the notified services. The main entries are GTA, individual advocate or firm of advocates, arbitral tribunal, sponsorship, services by Central or State Government to a business entity, director (other than employee) services, insurance agent, recovery agent, copyright transfer by author, RBI committee, direct selling agent, and SEBI lending scheme. Notification 10/2017-IT(R) adds import of services from non-taxable territory.

Is self-invoicing mandatory under RCM and what is the time limit?

Yes, self-invoicing is mandatory for supplies from unregistered suppliers under Section 31(3)(f) CGST. Rule 47A, inserted by Notification 20/2024-CT dated 8 October 2024 and effective 1 November 2024, requires the self-invoice to be issued within 30 days from the date of receipt of the supply. A payment voucher must also be issued under Section 31(3)(g) at the time of payment.

Can ITC be claimed on RCM payments?

Yes, ITC on RCM is available under Section 16 read with Rule 36(1)(b) CGST Rules, provided the tax is paid in cash through the electronic cash ledger (Section 49(4) bars use of ITC for RCM payment) and the recipient holds a valid self-invoice or supplier invoice plus the payment voucher. Per Circular 211/5/2024-GST dated 26 June 2024, the relevant financial year for the Section 16(4) time limit is the FY of self-invoice issuance.

What is the time of supply for services received under RCM?

Per Section 13(3) of the CGST Act, amended via the Finance (No. 2) Act 2024, the time of supply for services under RCM is the earlier of (a) the date on which payment is made or recorded in the recipient's books, or (b) the date immediately following 60 days from the date of issue of invoice by the supplier (i.e., the 61st day). The earlier date triggers the GST liability.

Does RCM apply when a director receives sitting fees?

Yes. Per Notification 13/2017-CT(R) entry 6 read with Circular 140/10/2020-GST, sitting fees, commission, or consultancy paid to a non-executive or independent director attract GST under RCM, with the company as recipient liable to pay. Salary paid to a whole-time, managing, or executive director under an employer-employee relationship is outside GST under Schedule III.

How does RCM work for real estate developers?

Under Notification 7/2019-CT(R), a real estate promoter must procure at least 80% of project input value (excluding land, FSI, TDR, electricity, and cement) from registered suppliers. Any shortfall attracts RCM at 18%. Cement procurement from unregistered suppliers attracts 28% RCM regardless of the 80% threshold. The compliance must be tracked monthly with an annual true-up.

What is the cost of RCM compliance support at Patron Accounting?

Starting from INR 4,999 (Exclusive of GST and government charges) for the RCM diagnostic engagement covering a single entity with up to 50 vendors. Self-invoice and payment voucher framework setup, monthly managed compliance, real estate 80% tracking, and import-of-services advisory are quoted separately based on scope. Government fees apply only for departmental filings if needed.

RCM ka payment cash me hi karna padta hai kya?

Haan. Section 49(4) CGST ke under, RCM liability sirf electronic cash ledger se discharge ho sakti hai - ITC use nahi kar sakte. ITC RCM par baad me alag se claim hoti hai usi GSTR-3B me Table 4(A)(3) me, jab self-invoice aur payment voucher dono available ho.

Quick Answers

Who pays GST under RCM? The recipient of the supply, not the supplier - Section 9 CGST.
Is RCM ITC available? Yes - subject to cash payment of RCM under Section 49(4) and a self-invoice plus payment voucher under Rule 36(1)(b).
What is the self-invoice deadline? 30 days from receipt of supply - Rule 47A, effective 1 November 2024.
Does RCM apply on import of services? Yes - Section 5(3) IGST + Notification 10/2017-IT(R) covers all services from non-taxable territory.
Is registration mandatory for RCM? Yes - Section 24(iii) CGST mandates registration regardless of threshold.
What is the GTA forward charge option? 12% with full ITC by filing Annexure V at the start of the FY - Notification 5/2022-CT(R).

Why Move Now on RCM Compliance

RCM is the single most common audit finding in statutory and departmental GST audits.

Interest at 18% per annum runs from the original due date. The Rule 47A 30-day self-invoice rule (effective 1 November 2024) is being actively checked by tax officers. Voluntary disclosure under Section 73(5) before an SCN waives the penalty entirely.

The cost of an RCM diagnostic - starting from INR 4,999 - is a fraction of the typical demand for a single-year shortfall.

Built Into Nearly Every Expense Line

Reverse Charge Mechanism is built into nearly every business expense line - GTA freight, advocate retainers, director sitting fees, sponsorship payments, foreign SaaS subscriptions, real estate URD procurement, and e-commerce passenger transport.

The compliance toolkit has tightened materially since 2024 with Rule 47A 30-day self-invoicing, amended Section 13(3) time of supply, and the Circular 211/5/2024-GST ITC clarification. Patron Accounting LLP, with CA and CS professionals practising for 15+ years across Pune, Mumbai, Delhi, and Gurugram, issues RCM diagnostics, builds the self-invoice and payment voucher framework, tracks the real estate 80% rule monthly, and represents taxpayers from departmental scrutiny through GSTAT and writ jurisdiction.

Pair it with core GST Returns, a periodic GST Audit, expert GST Notice representation, and your annual GST Annual Returns.

📞 Call +91 945 945 6700 💬 WhatsApp Us ✉️ Email Us

Book a Free Consultation - No Obligation.

RCM Compliance Support Across India

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

RCM Compliance Support by City

Vendor mapping, self-invoice setup and GSTR-3B reconciliation, 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 new CBIC notification under Section 9(3) / 9(4) / 9(5), an amendment to Rule 47A or the self-invoice rules, an AAR/GSTAT/High Court ruling on RCM scope, or an ITC time-limit clarification post Circular 211/5/2024-GST.

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