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Use the checklist below to screen each inward purchase, create an audit trail, report the amount in the correct return period and assess input tax credit separately. GST rules and notifications can change, so verify the currently effective provision for the transaction date.
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What reverse charge means in GST
CBIC’s Sectoral FAQ defines reverse charge as the arrangement in which “the liability to pay tax is on the recipient of supply of goods or services instead of the supplier of such goods or services in respect of notified categories of supply.” The important limiting phrase is notified categories. Reverse charge is therefore a legal classification exercise, not a blanket rule for every purchase made from an unregistered person.
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The recipient’s responsibility can involve identifying the transaction, determining the applicable CGST/SGST/UTGST or IGST treatment, issuing documents where the law requires, paying the tax, reporting it in the return and preserving evidence. Whether the recipient can later claim input tax credit is a separate question.
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When is RCM applicable?
RCM applies when the precise inward supply falls within an operative notification made under the GST law and the stated conditions are met. The result can depend on all of the following:
- What was supplied, including the correct goods or service description and classification.
- Whether the supplier is registered, unregistered or has another status relevant to the notification.
- Whether the recipient belongs to the class named in the notification.
- The supplier’s and recipient’s locations and the place-of-supply facts.
- Whether the supply is treated as intra-State or inter-State and therefore involves CGST with SGST/UTGST or IGST.
- The notification entry, exclusions, thresholds or other conditions that apply on the transaction date.
The CBIC notification index records amendments over time. A historical list copied into a spreadsheet is not enough to establish current taxability or rate. Check the notification and amendments that were operative for the relevant period, and obtain transaction-specific advice when the facts are unusual or the classification is uncertain.
RCM screening checklist at a glance
| Checkpoint | What to verify | Evidence to retain |
|---|---|---|
| 1. Applicability | Supply description, parties, locations and operative notification entry | Purchase record, classification note and notification reference |
| 2. Documents | Supplier invoice status and any recipient-issued documents required by law | Invoice, self-issued invoice where applicable and payment voucher |
| 3. Timing | Statutory time-of-supply rule for goods or services | Receipt, payment and invoice dates |
| 4. Liability | Taxable value, rate, tax components and tax period | Calculation sheet and accounting entry |
| 5. Reporting | RCM amount included in the relevant GSTR-3B workflow | Filed return, workings and reconciliation |
| 6. Credit | Eligibility, business use, documentation and blocked-credit or apportionment rules | ITC assessment and supporting records |
Step 1: Screen every inward purchase against the current notification
Describe the actual supply
Start with the commercial facts, not a label such as “professional fee” or “vendor expense.” Record what was supplied, the contract or purchase-order description, the relevant classification and when the goods or service was received. A precise description helps you compare the transaction with the wording of a notification entry.
Identify both parties
Capture the supplier’s legal name, GST registration details and status on the date of receipt. Record your own registration and recipient classification as well. Some entries apply only when the recipient belongs to a specified class, so the same type of purchase can produce different outcomes for different businesses.
Establish location and tax type
Document the supplier location, recipient location and place-of-supply facts. Decide whether the transaction is intra-State or inter-State under the applicable provisions, then identify whether the liability is reported as CGST and SGST/UTGST or as IGST. Do not infer the tax type from the supplier’s address alone.
Read the operative entry and conditions
Save the notification number or entry you relied on, its effective date and any amendment that changes the wording, scope or rate. Confirm that the transaction satisfies every condition and is not covered by an exclusion. If you cannot map the facts to a current entry, flag the item for a GST practitioner or chartered accountant instead of assuming that RCM applies.
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Step 2: Record the determination before posting the purchase
Create a short RCM decision record for each transaction or homogeneous batch. At minimum, include:
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- Recipient registration and category.
- Plain-language supply description and classification used.
- Supplier, recipient and place-of-supply locations.
- Notification entry, amendment and effective date reviewed.
- Conclusion: RCM applies, does not apply or requires review.
- Taxable value, applicable rate, CGST/SGST/UTGST or IGST split and calculated amount.
- Time-of-supply dates and the return period selected.
- Document numbers and links within your accounting records, where available.
Registered-person accounting rules include tax payable under sections 9(3) and 9(4), tax collected and paid, input tax and ITC claimed. Your accounting system should therefore allow the RCM liability and any credit claim to be traced back to the underlying purchase rather than buried in a generic expense account.
Step 3: Check invoice and payment-voucher duties
Supplier invoice marking
A supplier invoice is required to indicate whether tax is payable on reverse charge. Check the invoice field and retain the document even when the supplier has not charged tax. A missing or incorrect marking should be investigated; it does not, by itself, decide whether the statutory RCM conditions are met.
Recipient-issued invoice in specified cases
For specified cases in which the recipient is liable under section 9(3) or section 9(4) and receives the supply from a supplier who is unregistered on the date of receipt, section 31(3)(f) of the CGST Act requires the recipient to issue an invoice. The Act states that “a registered person who is liable to pay tax under sub-section (3) or sub-section (4) of section 9 shall issue an invoice in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both”. Apply the statutory conditions and the corresponding State or IGST provisions to your facts; do not treat this sentence as a rule covering every unregistered purchase.
Payment voucher
The same specified framework requires a payment voucher at the time of payment to the supplier. Keep the voucher tied to the invoice, payment proof and accounting entry. If the transaction is settled in instalments or through an advance, make sure the document trail reflects the relevant payment events.
Step 4: Determine the correct time of supply and tax period
Do not automatically use the supplier invoice date. Work through the statutory time-of-supply rule for goods or services and write down the dates that drive the result:
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- Date the goods or services were received.
- Date payment was made, including the payment evidence.
- Date of the supplier invoice or the recipient-issued invoice, where relevant.
- Any other date specified by the applicable time-of-supply provision.
Goods and services can have different timing rules. CBIC’s FAQ describes familiar timing principles, but the CGST Act, amendments and transaction facts control. Once the time of supply is established, assign the liability to the corresponding return period and preserve the calculation used.
Step 5: Calculate the RCM liability
Calculate RCM on the taxable value determined under the GST valuation rules and apply the rate that is operative for the notified supply and period. Show the components separately: taxable value, rate, CGST and SGST/UTGST or IGST, and total tax payable. If the consideration includes elements that affect valuation, document how you treated them instead of relying on a rounded vendor amount.
A practical worksheet can use this sequence:
- Enter the transaction value and identify any valuation adjustments required by law.
- Confirm the notification entry and rate effective on the time-of-supply date.
- Calculate the tax component and split it into the correct State or IGST components.
- Compare the result with the purchase register, general ledger and payment record.
- Have an adviser review unusual classifications, related-party values or transactions spanning multiple periods.
Never use a remembered rate or an old spreadsheet without checking its effective date. The notification index and amendments are the controlling references for the particular supply.
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Step 6: Pay and report the liability in GSTR-3B
Include identified RCM supplies in the return workflow for the period in which the liability arises. Reconcile the transaction register to the inward-supply reverse-charge section in GSTR-3B, and verify that the tax paid in the return agrees with your calculation sheet and ledger.
Use the live GST portal form and current filing instructions for the relevant tax period. A historical copy of GSTR-3B can show the general structure of the return, but it is not proof of the current portal workflow or field labels. Before filing, check:
- Every RCM transaction selected for the period has an underlying decision record.
- The CGST/SGST/UTGST or IGST split agrees with the place-of-supply analysis.
- The amount reported in GSTR-3B agrees with the tax payment and accounting entry.
- Items deferred because of missing documents are tracked for the next review.
- Corrections to earlier periods are documented and approved.
Step 7: Assess input tax credit separately
Paying GST under RCM does not automatically create an ITC entitlement. CBIC’s FAQ confirms that tax paid under reverse charge can be input tax, subject to the applicable law. Before claiming credit, test the statutory conditions and restrictions, including receipt of the goods or services, business use, required documentation, payment of the tax and any blocked-credit or apportionment rule.
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Keep the liability assessment and the ITC assessment as two linked but separate decisions. A transaction may require RCM payment while the related credit is wholly blocked, partly apportioned or claimable only after a condition is met. Record the amount claimed, the period of claim and the reason any portion was not claimed.
Step 8: Reconcile and retain an audit trail
At month-end or another defined close, tie together four records: the purchase documentation, the RCM calculation, the tax payment and the return reporting. Then reconcile any ITC claim to the same transaction. Retain amendments, review notes and correction entries so a later reviewer can understand why the original conclusion was reached.
A physical purchase ledger or bookkeeping register can help organise a paper workflow, but the accounting rules do not prescribe a particular bound ledger product. An electronic register is acceptable when it preserves the required details, is retrievable and supports an audit trail.
How to compare two purchases without overgeneralising
When two transactions look similar, compare them across the same seven axes rather than deciding from the supplier’s registration status alone:
- Supply type and classification.
- Supplier status and recipient class.
- Supplier, recipient and place-of-supply locations.
- Operative notification entry and every condition or exclusion.
- Taxable value and rate.
- Time of supply and return period.
- ITC eligibility, restrictions and apportionment.
This matrix prevents the common mistake of treating “purchase from an unregistered supplier” as a complete RCM test. The legal outcome depends on the combination of facts and the notification in force for that period.
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Assuming every unregistered purchase is RCM
Fix: Start with the notified category and recipient conditions. Record the entry checked and the reason it applies or does not apply.
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Using an old notification list
Fix: Check the CBIC notification index and amendments effective on the time-of-supply date. Save the version or reference used in your file.
Reporting from the supplier invoice date alone
Fix: Apply the statutory goods or services time-of-supply rule using receipt, payment and invoice dates.
Charging the liability to an expense account without a tax trail
Fix: Post separate tax components and retain the calculation, payment proof and GSTR-3B reconciliation.
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Claiming ITC automatically after paying RCM
Fix: Perform a separate eligibility test and document blocked or apportioned amounts.
Relying on a historical GSTR-3B screenshot
Fix: Follow the live portal form and current filing instructions for the relevant tax period.
A repeatable monthly operating routine
- Export or collect all inward purchases, including items received without a supplier tax charge.
- Filter for supplies that could match a notified RCM category.
- Complete the supplier, recipient and location fields for each candidate.
- Review the operative notification and record the conclusion.
- Prepare recipient invoices and payment vouchers where the statutory conditions require them.
- Calculate the liability using the correct time-of-supply period and tax components.
- Post the accounting entries, pay the tax and reconcile to GSTR-3B.
- Assess ITC independently and retain the supporting documents.
- Escalate uncertain, amended or unusual transactions to a qualified adviser before filing.
What to do when the facts are unclear
Pause the filing decision when the supply description is ambiguous, the notification has changed, the place of supply is disputed or the recipient category is uncertain. Gather the contract, invoice, delivery or service evidence, payment dates and registration details. Ask a GST practitioner or chartered accountant to review the classification and effective notification, and retain the written conclusion with your records. This is safer than applying a broad “all unregistered purchases” rule and attempting to correct the return later.
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