Dear Sir, one of my client has registered under GST. he wants to purchase from unregistered dealer. my question is:

1. whether he has to pay RCM under section 9(4)? is any extension date for RCM under 9(4)?

2. is any cash limit for purchase from URD?

3. whether any specific format of Invoice for URD purchase? is any additional details to be mentioned on invoice for purchasing from URD?

4. if purchased from URD is it mandatory to show in GSTR 3B or optional ?

5. is additional documents to be maintained for URD purchase ? Kindly guide Thanking you

Reply—

1. Provision of section 9(4) of CGST Act, i.e. Reverse charge mechanism in case of purchases made from Unregistered person (amount more than Rs. 5000/-) was operative upto 12.10.2017. As per notification No. 38/2017 CT (Rate) dated 13-10-2017, all supplies from Unregistered person are exempted without any threshold limit. 

The subsequent Notifications no. 22/2018-Central Tax (Rate) dated 06-08-2018 has extended the exemption from tax liable under the reverse charge basis under section 9(4) till 30-09 2019. This notification has been rescinded by CBIC

And as per CGST (Amendment ) Act, 2018, provision of section 9(4) has been amended and now Reverse charge is not applicable on all inward supplies received from Unregistered supplier. 

2. No

3. No

4. It is not clarified anywhere that it is optional to fill details of inward supply from unregistered dealer while filing GSTR-3B, there is no separate column to show these inward supplies, so in our opinion, it is not required.

5. No