Applicability of GST under RCM on CFO renewal fees paid to KSPCB

[TEAM GST]

A Sugar factory has paid to Karnataka State Pollution Control Board (KSPCB) towards Consent for Operation (CFO) renewal fees. KSPCB has not provided any GST tax invoice, only online payment receipt from the KSPCB portal is available.

Kindly advise whether GST is applicable under RCM or this would be exempt under the ambit of Sl no 4 Notification 12/2017

AI Summary

CFO renewal fees may qualify as environmental-function exemptions, though reverse-charge liability depends on characterising consent as registration or authorisation.
CFO renewal fees may be treated as exempt where the Pollution Control Board's consent-related regulatory service is linked to environmental protection, a municipal function under Article 243W; on that view, reverse charge does not apply and the taxpayer should preserve payment, consent and fee records supporting the exemption. A contrary interpretation treats CFO as an authorisation rather than registration, making GST payable under reverse charge with self-invoice and payment-voucher compliance. Treatment depends on the statutory nexus, characterisation of the service and relevant tax period.