Our client has received service of GTA both registered and unregistered. They have received invoices from registered and unregistered except a few unregisterd transporters who are paid cash. My questions are 1. whether RCM self invoicing must be done for all the RCM payments including service received from registered transporters? 2.When RCM invoice be done? on the date of accounting of the invoice or on the date of payment of RCM tax to government? 3.Can we issue consolidated monthly self invoice?

Reply—1. As per section 31 (3) (f) of the CGST Act, a registered recipient who is liable to pay tax under RCM is required to issue an invoice in respect of goods or services received by him from the supplier who is not registered on the date of receipt of goods or services or both, accordingly the responsibility of issuing invoice in case of RCM is cast on the recipient and the last date for issuance of such an invoice is on the date of receipt of goods or services.

Further, a registered person who is liable to pay tax under sub-section (3) or sub-section (4) of section 9 shall issue a payment voucher at the time of making payment to the supplier.

Taxes paid under RCM, shall not be appearing in FORM GSTR-2A. The recipient is to claim ITC on the basis of self-generated invoice as per section 31(3) (f) of the CGST Act, subject to payment of tax.

The credit of tax paid under RCM can be taken in accordance with section 16 of the CGST Act, subject to section 17 thereof. The credit can be taken when the invoice is raised as per section 31(3) (f) of the CGST Act. Obligation to make payment of tax under RCM is casted on the recipient.

2. As per Rule 46 of CGST Rules, where an invoice is required to be issued under clause (f) of sub-section (3) of section 31, a registered person may issue a consolidated invoice at the end of a month for supplies covered under sub-section (4) of section 9, the aggregate value of such supplies exceeds rupees five thousand in a day from any or all the suppliers.