As you all are aware, RCM was applicable on renting out immovable property (excluding residential accommodation) by unregistered persons to registered persons – this meant that all GST registered recipients (including composition tenant) had to pay 18% GST under RCM.
The disadvantage of this to composition taxpayers was that they could not avail ITC of this 18% GST RCM discharged.
But, now CBIC vide Notification No. 07/2025 – Central Tax (Rate) – dated 16th January 2025 – based on the proposals of the 55th GST Council Meeting – has excluded composite taxpayers from this RCM where they have taken a rented premise from an unregistered person.
✅ Tomorrow is the last date for CMP-08 form (Quarter 3), so be aware and do not pay RCM of such rental properties.
✅ Note that if you have filed any CMP-08 before today – taking into account and after paying this RCM, then you will not get any GST refund.
✅ Similarly, if you have not paid such RCM in your CMP-08 filed before today, then also no SCN or Order will be served upon you by the GST Department alleging that this RCM has not been discharged.
✅ This is because the GST Council had made it clear in its 55th Council Meeting that regularisation of this provision will be done on “as is where is” basis.
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