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Applicability of RCM on ROC Fees and DGFT Fees

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....pplicability of RCM on ROC Fees and DGFT Fees<br> Query (Issue) Started By: - Bhavesh Suthar Dated:- 27-6-2025 Last Reply Date:- 29-6-2025 Goods and Services Tax - GST<br>Got 6 Replies<br>GST<br>We are a private limited company with turnover of more than 500 Crs. We have applied for TRQ license and paid DGFT fees of Rs. 1 lakh for the application of this license which is renewed every year. Wil th....

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....e DGFT fees be liable to GST under RCM. Currently, we are discharging GST on ROC fees under RCM. Also what is the difference between Sl. no. 6 & 9 of Notification 12/2017 dated 28.06.2017. Reply By Padmanathan KV: The Reply: In my opinion, it is advisable RCM and take ITC. As i understand, Sl no. 6 exempts Govt services for non-business entity. Sl No. 9 exempts Govt services below Rs. 5000/-. Si....

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....milarity in both these entries are that, it does not cover: (a) services by the Department of Posts&nbsp;and the Ministry of Railways (Indian Railways);&nbsp; (b) services in relation to an aircraft or a vessel, inside or outside the precincts of a port or an airport;&nbsp; (c) transport of goods or passengers; or Reply By KASTURI SETHI: The Reply: (i) GST is applicable on DGFT fee under R....

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....CM and is to be paid by the recipient (business entity) for receipt of service from Central Govt department (DGFT) provided as public authority. Covered under serial no. 5 of Notification No. 13/17-CT(R) dated 28.6.17 as amended. This transaction/service does not fall under exception clause mentioned in the said Notification and this transaction is also covered in the definition of "business" unde....

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....r Section 2 (17) (i) of CGST Act which extracted below: "any activity or transaction undertaken by the Central Government, a State Government or any local authority in which they are engaged as public authorities". (ii) There are various exemptions admissible in terms of Notification No.12/17-CT (R) dated 28.06.17 as amended. See also Serial No.47 (a) of Notification No.12/17-CT (R) dated 28.06....

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.....2017. In case you are not eligible for any of the exemptions provided in the above Notification, DGFT fee is liable to GST under RCM. Reply By Padmanathan KV: The Reply: Please read the first line as "advisable to pay RCM and take ITC" Reply By Sadanand Bulbule: The Reply: I welcome the replies of both experts. Follow them. Reply By Shilpi Jain: The Reply: There is a small difference - ent....

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....ry 9 does not have "(d) any service, other than services covered under entries (a) to (c) above, provided to business entities." - So the 5k exemption will be applicable to all other services except the ones mentioned specifically in entry 9.&nbsp; Though for the a, b and c in entry 6, it looks like it will be covered under 6 and 9. In case where services fall under more than one entry, the taxp....

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....ayer is free to chose the entry that is most beneficial for it. &nbsp; Reply By KASTURI SETHI: The Reply: Difference Serial No. 9 contains the factum of continuous supply of service&nbsp;and&nbsp;threshold limit of Rs. 5000/- whereas both are not available at serial no. 6. Hence the difference in both situations.&nbsp;<br> Discussion Forum - Knowledge Sharing ....