Chartered Accountant · ICAI M.No. 153926 · FRN 136869W · Reviewed on 7 October 2026
The section 9(3) list, business edition
Beyond the big five: arbitral tribunal fees; services from the government (including renting of government premises to a registered person); residential dwellings rented to a registered person (since 18 July 2022 — the flat taken for a director or employee is the classic catch); renting of motor vehicles designed to carry passengers, from a non-corporate operator charging 5%, to a body corporate; import of any service for business (overseas software, consultancy, Google/Meta-type invoices billed from abroad); and metal scrap bought from unregistered suppliers, added from October 2024.
The mechanics people miss
RCM liability is payable in cash only — your ITC balance cannot discharge it. Where the supplier is unregistered, you must raise a self-invoice (section 31(3)(f)); time of supply for services is broadly the earlier of payment or 60 days from the supplier’s invoice. The tax you pay is then available as ITC in the same month, provided section 17(5) does not block that category — so for most items RCM is a cash-flow loop, not a cost.
Where it bites in practice
Advocate bills carry no GST line, so the liability is invisible until a notice arrives; sponsorship of a conference gets booked as marketing; the director’s flat rent hides in perquisites; and composition dealers forget that RCM applies to them too — at full rates, with no ITC to soften it. An expense-ledger RCM sweep is part of every return cycle in our GST compliance practice.