gst on real estates and - s-cme · services in relation to immovable property, boat or vessel...
TRANSCRIPT
Impact and Implication of GST on Real Estates and Construction Contracts –Existing and Future
Vishnu Daya & Co.
Index
Overview of GST
• Why GST?
• Taxes Subsumed under GST
• GST Concept
• How GST Works?
Certain Key Provisions of GST
• Meaning and Scope of Supply
• Schedule I & II
• Place of Supply and Time of Supply
• Composition Scheme
Compliances Under GST
• Input Tax Credit
• Registration
• Returns filing
• E-way bill
• Invoice
GST Impact
• Current taxing provision for a works contractor in regular scheme with sub contractor and without sub contractor Vis-à-vis- GST
• Current taxing provision for a works contractor when registered under composition scheme vis-à-vis GST
Vishnu Daya & Co.
Index
GST Impact
• Classification and supply of apartments on own land developed by land owner cum developer.
• Classification and taxation of JDA
• Construction on own land
• Only developer as contractor
• Supply of manpower
• Valuation
• Revenue sharing Vs Area sharing
• Outsourcing of end to end construction activity
• Advance paid Vs Advance received?
GST Impact
• Purchase return
• Reduction in the purchase bills
• Sending inputs for job work
• Providing various facilities in the work site
• Retention amount
• Switching over from one apartment to another
• Cancellation of apartment
• Sale by individual to third party and consenting party by developer
• Buyback contracts
• Inter-state works contract
Vishnu Daya & Co.
Index
GST Impact
• URD purchases
• High sea sales
• Construction to SEZ, EOU and STPI
• Government projects and low cost housing
• Reverse charge mechanism
• Transition credits
• Precautions
Vishnu Daya & Co.
Overview of GST
Vishnu Daya & Co.
Why GST?
Questions with the current taxation regime
Excise Duty – Not creditable through the
supply chain
Service Tax – Not creditable to the traders
VAT – Not creditable to the service providers
CST – cost to all
Several more local taxes not creditable
Different tax rates across country
Discriminatory exemptions
How GST addresses the same?
Seamless credit throughout the supply
chain
Single tax rates across the country
Easy movement of goods and free
trade across the country
Vishnu Daya & Co.
Taxes to be subsumed under GST
Excise Duties including the
additional excise duties
Cesses in the nature of
excise duty /customs duty
Additional duties of customs
(i.e. CVD and SAD)
Central Sales Tax
Service Tax
Cesses and surcharges levied
by Union i.e. SBC & KKC
VAT/ Sales Tax
Entry Tax not in lieu of
octroi
Entertainment Tax (unless
levied by the local bodies)
Luxury Tax
Taxes on lottery, betting
and gambling
Cesses and surcharges
levied by States, related to
supply of goods and
services
Central Levies State Levies
GST
Vishnu Daya & Co.
Taxes Not
Subsumed
Vishnu Daya & Co.
Central Taxes
Export duties and Basic Customs Duty
Terminal Taxes on goods and passengers, carried by rail, sea or air
Security Transaction Tax
Taxes on Petroleum Products
Alcohol Products
State Taxes
Stamp duties
Taxes on land and Buildings
Electricity tax
Taxes on vehicles
Tolls
Profession tax
Taxes on Petroleum Products
Alcohol Products
GST in India – Destination Based Taxation – Dual GST
CGST
• On intra-State Supply
SGST
• On intra-State Supply
UTGST
• On intra-State Supply
IGST
• On Inter-state Supply
OR
The location of the Supplier and the Place of
Supply are in same State – Intra-state Supplies
The location of the Supplier and the Place of
Supply are in different State – Inter-state
Supplies
Exception : IGST applies to Import, SEZ
developer/unit and tourist
Vishnu Daya & Co.
Certain Key
Provisions of
GST
Vishnu Daya & Co.
Goods – Section 2
(52)
Every kind of movableproperty other thanmoney and securities butincludes actionable claim,growing crops, grass andthings attached to orforming part of the landwhich are agreed to besevered before supply orunder a contract ofsupply;
Vishnu Daya & Co.
Works Contract –
Section 2 (119)
A contract for building,
construction, fabrication,
completion, erection, installation,
fitting out, improvement,
modification, repair, maintenance,
renovation, alternation or
commissioning of any
immovable property wherein
transfer of property in goods
(whether as goods or in some
other form) is involved in the
execution of such contract
Vishnu Daya & Co.
Questions
Whether construction of part ofbuilding is works contract?
Is it works contract, when separatevalue for supply and installation of ACis provided?
Whether supply and installation ofelevator is a works contract?
Whether comprehensive maintenanceof elevator is a works contract?
Vishnu Daya & Co.
Composite supply
A supply made by a taxable person to
a recipient consisting of two or more
taxable supplies of goods or services
or both, or any combinations thereof,
which are naturally bundled and
supplied in conjunction with each
other in the ordinary course of
business, one of which is a principal
supply
Vishnu Daya & Co.
Meaning of Principal supply
The supply of goods or services which constitutes the predominant
element of a composite supply and to which any other supply forming part
of that composite supply is ancillary
Vishnu Daya & Co.
Examples of
composite supply
Questions
Supply of goods with additional charge for
transportation, insurance, packing, loading etc.
Supply and installation of machinery
Medical consultancy and dispensary (provided both are
taxable)
Professional fees for services and claiming
reimbursements
Whether supply and installation is a composite supply or
works contract?
When the single contract is given to factory located in
different State, but the installation is done by the branch,
whether the same would be classified as works contract in the
hands of factory as well as branch?
Vishnu Daya & Co.
Mixed supply
– 2(74)
Two or more individual supplies of goods or services or any
combination thereof, made in conjunction with each other by
a taxable person for a single price where such supply does
not constitute a composite supply
Various marketing schemes – either bundled or unbundled
Sale of school bag, water bottle and stationery for one price
Examples:
Vishnu Daya & Co.
Consideration 2(52)
Any payment made or to be made, whether in money or otherwise, inrespect of, in response to, or for the inducement of, the supply ofgoods and or services, whether by the said person or by any otherperson;
The monetary value of any act or forbearance, whether or notvoluntary, in respect of, in response to, or for the inducement of, thesupply of goods and or services whether by the said person or by anyother person;
Provided that a deposit whether refundable or not, given in respect ofthe supply of goods and or services shall not be considered aspayment made unless the supplier applies the deposit as considerationfor the supply.
Exclusion: Subsidy by the Government
Vishnu Daya & Co.
Implications of consideration
What definition says
Advance payment made at the time of
JD agreement to owner- non
refundable
Bonus offered to person to join
employment before his normal
relieving period
Free supply of design to a fabricator
Amount paid to the tenants to vacate
the land and building
How it will effect?
To induce the owner to sign JD
agreement
To induce the person to join
employment- Not employer employee
relationship exists
Monetary value of the act
To induce a person to vacate-
Precaution??
Vishnu Daya & Co.
Money- 2(75) Means
The Indian legal tender or any foreigncurrency, cheque, promissory note, bill ofexchange, letter of credit, draft, pay order,traveller cheque, money order, postal orelectronic remittance or any otherinstrument recognized by the RBI whenused as a consideration to settle anobligation or exchange with Indian legaltender of another denomination but shallnot include any currency that is held forits numismatic value
Vishnu Daya & Co.
Meaning of otherwise used in consideration
Barter
Exchange
Any other mode
Any mode Government may notify
Vishnu Daya & Co.
Meaning and Scope of Supply
Supply Includes
All forms of supply
Supply Specified in Schedule I
Import of Services
All forms of supply –
Such as sale, transfer,
barter, exchange,
license, rental, lease or
disposal made or agreed
to be made for a
consideration by a
person in the course or
furtherance of business
Supplies made without
consideration
For a consideration and
whether or not in the course
or furtherance of business
Vishnu Daya & Co.
Schedule I
Permanent transfer/disposal of business assets where input credit has been
availed;
Supply between the two or more distinct or related persons within or outside
the State – Exception gift to employees less than Rs.50K
Supply of goods by principal to agent – where agent undertakes to supply
goods on behalf of principal
Supply of goods by an agent to principal – where agent undertakes to
receive goods on behalf of principal
Importation of services by taxable person from a related person or from any
of his other establishments outside India, in the course or furtherance of
business
Vishnu Daya & Co.
Schedule II – Construction Service declared as
Service
Construction of a complex, building, civil structure or a
part thereof, including a complex or building intended for
a sale to a buyer, wholly or partly, except where the
entire consideration has been received after issuance of
completion certificate, where required, by the competent
authority or after its first occupation, whichever is
earlier
Vishnu Daya & Co.
Relevance of
declared service
Should be classified as service only and
not under any other category like supply
of goods or supply of service or vice versa
or composite supply of goods or service
Rate of tax for declared service may be
different. For example, rate of GST for
construction is 12% without refund of
overflow of input credit
Questions Whether construction of road is a
construction service or works contract
service?
What is the classification of site
formation and sale of developed site?
What is the meaning of “part thereof ”
in construction service?
Whether the sub contract of
construction is a construction service or
works contract service?
Vishnu Daya & Co.
Questions Whether signing JD is a supply?
Whether demolition of site office at thetime of completion is a supply?
Whether agreeing to supply water,electricity and security at free of cost is asupply?
Whether supplying free of cost materialto the contractor is a supply?
Whether offering “free of costmaintenance for two years” is a supply?
Vishnu Daya & Co.
Questions under construction
Whether contractor can build a complex or building and classify under
construction service?
Whether a building partly for own use and partly for renting would fall
under construction service?
Whether sale of material is required in classification of construction
service?
Vishnu Daya & Co.
Place of Supply of Services
SITUATION PLACE OF SUPPLY
In respect of services excluding specific
categories:
When provided to registered person for
services
Service provided to an unregistered person
Location of the service receiver when
provided to registered person
Location of the recipient, where the
address on record exists. (In other cases,
location of the supplier)
Services in relation to Immovable property,
boat or vessel including ancillary services
Location of the immovable property or boat
or vessel
Transportation of goods including by mail or
courier
In case of registered person, Location of
such service receiver.
In other cases, location at which goods are
handed over for transportation
Vishnu Daya & Co.
Questions If you appoint an architect from Bangalore for a
project in Coimbatore and billing to client in
Bangalore, what type of tax architect should charge?
Whether credit of the above is available?
Whether the view will change when architect is from
Singapore?
Whether the GST paid on Hotel located in another
State can be claimed in Karnataka?
When inter-state works contract is undertaken,
whether registration is to be obtained in that State?
When an apartment in Bangalore is billed to a buyer
from Delhi, what type of tax should be charged?
Vishnu Daya & Co.
Place of Supply of Goods
Situation Place of Supply
Where supply involves movement of
goods
Location where movement of goods is
terminated (Place of Delivery)
Where goods are delivered before or
during the movement of goods either by
way of transfer of documents or title to
the goods or otherwise, to the recipient
or any other person on the direction of
a third person (Bill to Ship to cases)
Principal place of Business of such
Third person
Where supply does not involve the
movement of goods
Location of such goods at the time of
delivery to the recipient.
All other cases As determined by the law made by the
Parliament on recommendation of the
Council
Vishnu Daya & Co.
Bill to Ship to Transactions
Vishnu Daya & Co.
Factory
in B’lore
Delivery address –
Chennai
Billing address
– Mysore
CGST + SGST Factory in
B’lore
Delivery address
– B’lore
Billing address –
Chennai
IGST
Relevance In case of inter-state works contract,
supply to the work site by a local supplier
is an inter-state supply or local supply?
If registration in other State is not
obtained, whether the Government will
force to take casual dealer in the State?
Vishnu Daya & Co.
Meaning of casual person
A person who occasionally undertakes transactions involving supply of
goods or services or both in the course or furtherance of business, whether
as principal, agent or in any other capacity in a state or a Union territory
where he has no fixed place of business
Implications:
Compulsory registrations for casual taxable person.
Persons participate in exhibition cum sale
Conducting events, entertainments, etc.
Vishnu Daya & Co.
Place of Business- Means
A place from where the business is ordinarily carried on, and includes a
warehouse, a godown or any other place where a taxable person stores his
goods, supplies or receives goods or services or both; or
A place where a taxable person maintains his books of account; or
A place where a taxable person is engaged in business through an agent, by
whatever name called
Relevance: Due to the above, when you undertake interstate works contract,
the officer may force you to take registration in other state. Further other
business exigencies will force you to register which will be discussed later
Vishnu Daya & Co.
Time of
supply of
service
Vishnu Daya & Co.
Earlier of
Earlier of
Date of invoice – for
goods
Last date for issuing invoice - for services
Date of receipt of payment
Time of
Supply –
RCM –
Goods
Vishnu Daya & Co.
Earliest of the above
Date of receipt of
goods
Date of payment
30 days after the date of
invoice
Time of
Supply –
RCM –
Services
Vishnu Daya & Co.
Earliest of the above
Date of payment
60 days after the date of
invoice
Composition
Dealer
The turnover should be less than Rs.50,00,001.
It may be enhanced to Rs. 1 Crore
It is on all India based.
Applicable to the trader (1%), manufacturer (2%)
and hotelier (5%).
Service providers including works contractors
cannot for this.
Dealers cannot collect the tax
Invoice should specifically state that he is a
composite supplier
Title of the invoice is “bill of supply”.
Vishnu Daya & Co.
Precautions Should not purchase from composition
supplier
Should purchase when input credit is not
available
Vishnu Daya & Co.
GST Impact on
Real Estate Sector
Current Taxing Scheme – Regular
Excise duty paid on the purchases is part of cost
VAT paid to the sub contractor who is in regular scheme is available as input credit
VAT paid to the sub contractor who is in composition scheme is available as turnoverdeduction
Any excess tax collection on account of deduction of sub contractor will be forfeited
Claim labour and other like charges either on actual basis or standard rate
On the balance turnover, tax to be computed classifying steel and non steel turnover
Pay tax on URD purchases and avail the credit
Proof of payment of tax by sub contractor is must to claim turnover deduction
Matching principle for inputs exist
Vishnu Daya & Co.
Current Taxing Scheme – COT
Classification of purchase into inter-state, local, import and URD
Full tax to be paid on inter-state and import purchase based on classification
Full tax to be paid on URD purchase
Deduction towards sub contractor turnover (without GP and whether under regular orcomposition scheme) is allowed
COT is paid at full rate on the “cost” of inter-state and import purchase
On the balance turnover, pay COT @ 4%.
Pay tax at applicable rate on URD purchase
Proof of payment of tax and filing of return by sub contractor is required
No deduction towards labour and other like charges and also no input
Vishnu Daya & Co.
Service Tax for Regular and Composition Dealer
Classification Questions like works contract or construction service
Valuation rules for actual value or deemed value
Abatement notification
Valuation of free supply material
Various items to be included and excluded
Payment of tax on advance under ST and not under VAT
Timing of payment of ST on the owner portion
Vishnu Daya & Co.
Difficulties in the current model of VAT and service tax
In case of COT dealer under VAT, how to pay ST on actual basis?
When a person has sub contracted everything to a COT dealer, can he pay
the ST on actual basis?
Very arbitrary valuation rule for original work (40%) and other work (70%).
Whether the decision of L & T can be applied to service tax?
Meaning of actual value adopted.
Vishnu Daya & Co.
How GST will be
for the industry?
Classification as works contract orconstruction service
Both are declared as “service”
Flat rate of tax for works contract service@ 18%
Flat rate of tax @ 12% for constructionservice including the value of land
No refund of overflow of input tax incase of construction service
In case of works contract, refund ispermitted.
Invoicing
For collection of advances (mobilization or material
or any other type) – Raise advance receipt voucher
with the prescribed contents
For regular demand note – raise invoice on the
customer and charge applicable GST
Bifurcate the value between land and construction
Invoice should contain all the particulars stated in
the law
In case of invoice on/by contractors, raise the
invoice as per the terms of the contract
No concept called pro forma invoice
Any measurement variation – should be by way of
credit or debit note from the contractor/ supplier
Vishnu Daya & Co.
Consequence of
delay in invoicing
Attracts interest and penalty
If invoice prepared consequent to the visit of
the officer, the developer or recipient cannot
avail input credit on such invoice
May go for summary assessment
Other implication on delay in invoicing
Whether invoice can be deferred when tax is paid
on advance?
Vishnu Daya & Co.
Precautions
Check the contents of the invoice regularly
If any invoice issued for advance supply of goods, credit can be taken only
after the receipt of goods
For supply of goods- 3 sets and for supply of service- 2 sets
Misplacement of invoice, delay in accounting etc.- Counterproductive
Vishnu Daya & Co.
Classification of
various types of
contracts
Construction of complexes, building
Sale of residential unit by developer in aJD
Sale of residential unit by land owner ina JD
Sale of owner portion of the unit bydeveloper
Labour contract on piece rate basis
Sub contractor with material of a workscontract
Classification of
various types of
contracts
High sea sale of elevator to the SEZ
Annual maintenance of apartment/commercial building
Hire charges of cranes and other equipment
Supply and fixing of air conditioner
Electrical contracts
Supply and installation of lift
Site formation and sale
Road formation
Sale of UDS
Classification and
taxation of joint
development
agreement
Works contract Vs Construction
service?
Both are declared as service
Rate of GST for works contract @
18% with refund of excess input
credit
Rate of GST for construction @
12% including the land value without
overflow of input credit
Classification Under Current Law
Service Tax
Under service tax law, choice isgiven to the assessee to classifyeither construction service orworks contract service
If the land value is considered forassessable value, it is classifiedunder construction service
Excluding the land value, it wouldbe works contract service
VAT
No such concept of inclusive
of land value. VAT levies tax
only on the material
In case of JD, Commissioner
Circular No 9/2009 dated…
demands tax on the full value.
Going
forward
Whether construction service is a specific
entry for the sale of building or apartment
with land?
Since land is specifically mentioned as non
taxable item under GST, whether land value
can be considered for valuation purposes?
Whether works contract is directly related to
the transfer of property resulting into
immovable, based on the concept of GST,
whether WC is the right classification?
Vishnu Daya & Co.
Our View
It is possible to split the value towards land and building
When the construction is not commenced but advancesare taken towards land, it cannot be billed with 12% GST.When various other authorities demand invoice anddocument like bank for the purpose of loan, the invoiceor receipt should clearly mention it as land and notconstruction service
Since GST is on the goods and service and not on theland, in our view, it is still possible to classify the activityas works contract and charge GST @ 18% and claimrefund
Refer the matter to the advance ruling
Wait for the clarification
Also challenge the clarification as well as advance rulingif negative before the high court. Until then pay the taxunder protest
Vishnu Daya & Co.
Questions in JD Whether signing JD agreement involves
supply of service by the developer to the
land owner?
What is the current legal provisions?
Whether agreeing to construct is a
consideration?
Definition of consideration- does not
require consideration in money
Vishnu Daya & Co.
Taxation of Joint
Development
Agreement
On signing the contract, developer may have topay GST on the market value of theconstruction to land owner
Raise invoice on land owner and collect GST
Land owner may not be able to take creditimmediately as the service is not provided
The land owner will not be able to utilize thecredit immediately.
The developer will have to deposit the entireGST collected to the Govt due to NIL inputcredit
In the hands of developer, input credit willaccumulate and the same will not be allowed asrefund. Exception: Rate difference
Solution????
Vishnu Daya & Co.
Definition of business
Any trade, commerce, manufacture, profession, vocation, adventure,wager or any other similar activity whether or not for a pecuniarybenefit;
Any transaction or activity in connection with or incidental orancillary to above;
One time activity of the nature specified above
Supply or acquisition of goods including capital goods andservice in connection with commencement or closure ofbusiness
Provision by a club, association, society or any such body (for asubscription or any other consideration) of the facilities or benefits toits members;
Vishnu Daya & Co.
Business- definition
Admission for a consideration of persons to any premises
Services supplied by a person as the holder of any office which
has been accepted by him in the course or furtherance of his
trade, profession or vocation
Services provided by a race club by way of totalisator or a
license to book maker in such club; and
Any activity or transaction undertaken by the Central/ State
govt, local authority in which they are engaged as public
authorities
Vishnu Daya & Co.
Issues in the definition of business
Conversion of personal asset into business asset?
Introduction of capital asset by an individual to a firm
Amount payable by a person towards goodwill of a firm.
Vishnu Daya & Co.
Issues
Land owner may have to register under GST to sell his portion
of area
Though it may be a one time event, still it will fall within the
meaning of business
If landowner sells only one unit and retains rest of the units, it
will be a business
The decision of L & T- as an immovable property???
Vishnu Daya & Co.
Construction on
the own land
Classification – construction service or
works contract service will continue
If no amount is collected from
prospective customers until OC or
completion certificate, it will not be liable
for GST under any head
In the above case, input credit will not be
available
URD tax may have to be paid on goods
and services
Construction
as contractor
– Questions
Mobilization advance
Classification
Retention amount
Deductions
Penalties
Billing cycle
Input credit on supplies
RCM on URD and others
Vishnu Daya & Co.
Discussion on
Questions –
Mobilization
Advance
No difference between material advance
or mobilization advance
GST has to be paid immediately and
point of taxation is the date of receipt
Raise receipt voucher
Since it is a continuous supply service,
invoice can be raised on the recipient
Recipient can avail the credit
Vishnu Daya & Co.
Meaning of continuous supply of service
A supply of services which is provided or agreed to be provided
continuously or on recurrent basis, under a contract, for a
period exceeding 3 months with a periodic payment obligations
and includes supply of such services as the Govt. may subject to
such conditions, as it may, by notifications specify
Vishnu Daya & Co.
Examples and relevance of Continuous supply of service
Example
Works contract services
Retainer services
Consultancy services
Renting of commercial
properties
Relevance
For the purpose of raising
invoice
Follow the provision given
in Section 31(5) to raise
invoice
If due date for invoice is
not ascertainable, then
invoice should be raised for
the payment received.Vishnu Daya & Co.
Classification Composite supply Vs. Works contract
As long as the final structure is animmovable property, it will be a workscontract
If the same is part of the immovableproperty but removable withoutdamaging the structure, it may be acomposite supply. Eg. Supply andinstallation of sink or water taps,electrical fittings, etc.
Vishnu Daya & Co.
Retention
amount
Section 16 states that input credit will be available tothe recipient only if the “full” payment is made to thesupplier within “180” days of the invoice.
How to achieve this in case of retention amount?
Collect BG for the retention amount. Hence to encasha bank guarantee for the product defects, there mustbe a strong and clear agreement
Pay full amount and receive back the retention amount
Whether a clause can be inserted in the agreement thatretention portion of the work can be billed only afterthe defect liability period of … years?
Whether the contractors can be advised to bill net ofretention amount to avoid the confusions?
Whether encashment of BG or writing off theretention amount is liable for GST?
Vishnu Daya & Co.
Deductions from
the bill
Various amounts will be deducted such asdifference in measurement, quality issue, nontendered items, etc.
Any deduction from the invoice should by wayof “credit note” from the contractor to theprincipal or to main contractor. Similarly in caseof deduction from the purchase bill, thesuppliers have to issue credit note.
Credit note should contain the invoice referenceand all other particulars required by the law
The receiver of the credit note should reversethe input credit to allow the deduction ofoutput tax to the contractor
When the final customer is a factory whocannot take input credit, how system will crossverify the reversal of input credit?
Vishnu Daya & Co.
Penalties If any amount is deducted on account of
penalty, it may be treated as income in
the hands of recipient
Department may dispute the input credit
on the penalties
There is no inclusive tax concept under
GST. Tax has to be shown separately in
the invoice to get the benefit of tax
deduction
Vishnu Daya & Co.
Billing cycle
If the contract period is more than 90 days, itwill be treated as continuous supply of service.
There must be periodic payment cycle in thecontract based on performance.
As per the time of supply provisions, invoicehas to be raised based on amount received orterms of the contract whichever is earlier
There is no concept of proforma invoice
Invoice should contain all the particulars givenin Section 31
Two copies of invoice should be raised- one forthe buyer and another copy for own use
If there is delay in billing for whatever thereason and if department makes you to raiseinvoice, credit thereon will not be available tothe recipient
Vishnu Daya & Co.
Input credit on
supplies
Contractor will be eligible for the input credit on all
inputs, input services and capital goods
List of inputs and services not eligible are as under:
1. Motor vehicles except when used for transport of goods
2. Goods/ Services used for foods and beverages, outdoorcatering, beauty treatment, health services, cosmetics andplastic surgery, membership of a club, health and fitness;
3. Life insurance, rent-a-cab, health insurance except whereGovt. notifies the service as obligatory under any law;
4. Travel benefits extended to employees on vacation;
5. Goods/ Services used in the execution of works contractservices for construction of immovable property (excludingplant and machinery) – construction includes renovation,additions, repair, etc. to the extent capitalised;
6. Goods on which tax is paid under composition
7. Goods or services used for private consumption
Vishnu Daya & Co.
Conditions to avail the credit
Vishnu Daya & Co.
Supplier to make payment
to vendor within 180
days from the invoice date
Credit allowed to Supplier
Vendor has paid the tax and filed
the return within due date
Vendor has uploaded the
correct Supply details in website
Tax invoice is available –
invoice should contain all
information required
Goods/ Services received
How to utilize
credits?
INPUT
TAX
CREDIT TO BE UTILISED AGAINST
CGST SGST IGST
CGST a – 1ST Preference r a – 2ND Preference
SGST r a – 1ST Preference a – 2ND Preference
IGST a – 2ND Preference a – 3RD Preference a – 1ST Preference
Returns Due Date
Vishnu Daya & Co
• GSTR 1
• Outward supplies
10th of the following month
• GSTR 2
• Inward Supplies
15th of the following month • GSTR 3
• Consolidated return and payment of tax
20th of the following month
• GSTR 9
• Annual Return
31st December of the following Year
No changes can be made to the
returns after September of the
following year or after furnishing the
annual return, whichever is earlier
Questions Non filing of return by the supplier
Non uploading by the supplier
Goods supplied, advance paid butinvoice not received. Supplier pays thetax on advance basis
Rejection of material as such
Return of material after making inward
Details of non payment within 180 daysfrom the bill date to be reported inGSTR-2
Vishnu Daya & Co.
RCM and URD
Central Government will notify the list ofgoods and services liable for RCM withinthe State
Central Government will notify the list ofgoods and services liable for RCM whenprocured from outside the State
There will be separate list of goods andservices (notified goods and services) forRCM
Any goods or services purchased fromURD will be liable for GST
Questions in
URD
Classification and rate of tax
Preparation of tax invoice for the URD
Payment by cash and credit cannot be
utilised
Precautions:
Do not purchase the “manufactured
goods” from URD as it will enhance the
cost
Vishnu Daya & Co.
Supply of
manpower
It is not a works contract
Giving work on piece rate is not a works contract
Free supply material for the contractor- generally
is not a works contract. However at times, it may
be a works contract. Will be discussed separately
Manpower supply either to the construction
service or to the works contract service will be
taxed @ 18%.
Concept of Reverse charge mechanism has been
removed
Valuation
Construction service to be valued with land
Looks to be optional one. However needs a
clarification
Works contract service – only the
construction activity would be taxed.
There is no bifurcation of steel and non steel
items
No deduction towards labour and other like
charges
Vishnu Daya & Co.
Valuation
No deduction towards sub contractor
turnover
No composition scheme.
Decision of L & T will not hold good. It is
applicable only when the works contract is a
composite supply. Since it is declared as
service, decision will not hold good
Raise invoice to the value as per the terms of
the contract
Vishnu Daya & Co.
Valuation –
free issue
material
Decision of SC in the case of N M Goel will
hold good.
If the contract is inclusive of FOC material,
it will have to be taxed in the hands of
supplier as well as contractor.
No need to add any profit
Contract should be clearly drafted. If
required, an addendum to be made as and
when situation warrants
Vishnu Daya & Co.
Questions Free issue of water, electricity and
security services
Free issue of design to the various sub
contractors
Free service of common architect of
builder or developer
Free use of some capital goods
Free use of land for staying the
construction workers etc.
Vishnu Daya & Co.
Revenue sharing
Vs Area sharing
Area sharing will have lot of Questions
such as timing of payment of GST,
availability of credit to the land owner,
valuation, overflow of credit in the hands
of developer at the time of closure of the
project, registration of the owner under
GST, non applicability of L & T decision
etc.
Solution: Revenue sharing??
How the revenue
sharing scheme
works?
The land owner and developer will enter
into an agreement to share the revenue
generated out of the built up area
The payment from the buyer can either
go to the bank account of developer or
to the account of the owner directly,
depending upon the understanding and
agreement
Vishnu Daya & Co.
How RS will
resolve the issue
of JD
GST is not payable at the time of agreeingfor the revenue
Owner will be introducing the land ascapital
Builder will introduce his manpower andcapital
The entire project development will behanded over to developer so that entireproject will suffer GST
AOP can sell the units under constructionservice or under works contract service
Vishnu Daya & Co.
Possible
Questions
Revenue sharing arrangement may bea different person and hence it mayrequire registration
The parties may not agree to formpartnership or LLP.
If the same is a special purposevehicle like AOP, the member and theAOP will be different. There could bestamp duty for the transfer of land,which the parties may not like
Vishnu Daya & Co.
Definition of person
Includes an individual,
HUF,
a company,
a firm,
a LLP,
an AOP or a BOI, whether incorporated or not, in India or outside India,
any corporation established by or under any Central Act or Provincial Act or a
Government Company as defined in Section 2(45) of the Companies Act,
any body corporate incorporated by or under the laws of a country outside
India,
Vishnu Daya & Co.
Meaning of person
a co-operative society registered under the law relating to co-
operative societies,
local authority,
Central or a State Govt, society, trust and every artificial judicial
person not falling within any of the above
Vishnu Daya & Co.
Possible
Questions
Unsold inventory??
Owner may be interested to retain
certain units after the completion.
It is a new concept. Industry, advocates
and auditors have to understand the full
consequences
Vishnu Daya & Co.
Outsourcing Entire
Activity to
Contractor
The decision of SC in L & T may not hold
good due to the declaration of works
contract and construction service as
declared service
The main contractor may have to register
and pay tax and avail input credit on the
sub contractor turnover
Even the owner may have to register under
GST
Input Credit for a contractor when classified under works contractor
Works contractor is eligible for input credit on all inputs and
input services.
Restricted goods and services as discussed earlier
Majority of the inputs will be liable for 28% and few ill be liable
for 18% or 5%.
If the input credit is more than output tax, refund is permitted
Vishnu Daya & Co.
Questions Input credit relate to the sale of land
may be proportionately disallowed
Timing of payment of GST on the land
owner share
Valuation of the land owner share
Any input service credit directly relate to
the acquisition of land like brokerage
paid, land clearance document etc., may
not be available
Vishnu Daya & Co.
Input Service for a Developer when classified under construction service
Like works contract, credit of all services will be available
Since GST is payable including on the land, the rate of GST is 12%
As per rate of tax announced, there will not be refund of overflow of input tax
The overflow of credit can be adjusted to other products
It is not advisable to classify works contract as construction service based on
project to project
Vishnu Daya & Co.
When construction
classification can
be opted
When litigation free situation demands
When land value is very low
When the cost of overflow of input is
already built in the project cost
Number of projects are on hand
Abatement Method –
Current Structure
- Service Tax paid under
Notification No. 26/2012
- VAT paid under COT
- No need to segregate the value
for land and construction in the
agreement
Vishnu Daya & Co
ParticularsAmount
Service
Tax Rate
ST
Amount
VAT
Rate
VAT
Amount
Base Value
Sale Price 19,19,400 - -
UDS 1,91,400 - -
Construction 17,28,000 4.50% 86,373 4.00% 69,120
Other Charges - -
Water & Electricity
Charges 72,000 4.50% 3,240 4.00% 2,880
Maintenance Fund 43,200 15.00% 6,480 0.00% -
legal Charges 30,000 15.00% 4,500 0.00% -
PLC / Floor rise 36,000 4.50% 1,620 4.00% 1,440
Club Membership 1,00,000 15.00% 15,000 0.00% -
Car Park 1,50,000 4.50% 6,750 4.00% 6,000
Total Cost 23,50,600 1,23,963 79,440
Service Tax 1,23,963
VAT 79,440
Total Unit Amount 25,54,003
Tax payable 2,03,403
Impact on Output
Tax – 12% Rate
- Tax payable under computedunder construction services
- Under this category, value ofland should be included in thegross value
- Rate of tax is 12%
- Wherever agreement enteredunder the current regime underabatement scheme has to followthis method only.
- Excess input credit anythingremains after payment ofoutput tax will lapse
Vishnu Daya & Co
Particulars
Tax
RatesTax Value Amount
Base Value
Sale Price - 19,19,400
UDS - -
Construction 12.00% 2,30,328 19,19,400
Other Charges -
Water & Electricity Charges 18.00% 12,960 72,000
Maintenance Fund 18.00% 7,776 43,200
legal Charges 18.00% 5,400 30,000
PLC / Floor rise 18.00% 6,480 36,000
Club Membership 18.00% 18,000 1,00,000
Car Park 18.00% 27,000 1,50,000
Total Cost 3,07,944 23,50,600
GST 3,07,944
Total Unit Amount 26,58,544
Tax payable 3,07,944
Less: Input 2,32,161
Net Tax payable 75,783
Input Tax Credit – Current
Regime
Particulars Tax NatureTax
RateAmount Amount
Assessable
Value
Materials-Non-
steel ED + VAT 28.81 1,54,894 6,92,488 5,37,594
Steel ED + VAT 18.13 21,917 1,42,836 1,20,919
Sand & Jelly VAT 18.69 2,017 12,812 10,795
Labour charges Service Tax 15.00 50,601 3,37,338 3,37,338
Office expenses
Admin Charges Service Tax 15.00 13,500 90,000 90,000
Salary NIL - - 90,000 90,000
Finance Cost NIL - - 1,20,000 1,20,000
Selling Cost Service Tax 15.00 24,681 1,64,542 1,64,542
Total 2,67,610 16,50,017 14,71,189
- All purchases are
presumed to be local
- In case of COT – no
VAT input available
- No sub-contract
Vishnu Daya & Co
Regular Method – Current
StructureParticulars
AmountService
Tax Rate
ST
Amount
VAT
Rate
VAT
Amount
Base Value
Sale Price 19,19,400 - -
UDS 1,91,400 - -
Construction 17,28,000 6.00% 1,03,680 10.15% 1,75,392
Other Charges - -
Water & Electricity
Charges 72,000 6.00% 4,320 10.15% 7,308
Maintenance Fund 43,200 15.00% 6,480 0.00% -
legal Charges 30,000 15.00% 4,500 0.00% -
PLC / Floor rise 36,000 6.00% 2,160 10.15% 3,654
Club Membership 1,00,000 15.00% 15,000 0.00% -
Car Park 1,50,000 6.00% 9,000 10.15% 15,225
Total Cost 23,50,600 1,45,140 2,01,579
Service Tax 1,45,140
VAT 2,01,579
Total Unit Amount 26,97,319
Tax payable 3,46,719
Less: Input 1,85,296
Net Tax payable 1,61,423 Vishnu Daya & Co
Impact on Output Tax
– 18%
Particulars Tax Rates Tax Value Amount
Base Value
Sale Price - 19,19,400
UDS - 1,91,400
Construction 18.00% 3,11,040 17,28,000
Other Charges -
Water & Electricity Charges 18.00% 12,960 72,000
Maintenance Fund 18.00% 7,776 43,200
legal Charges 18.00% 5,400 30,000
PLC / Floor rise 18.00% 6,480 36,000
Club Membership 18.00% 18,000 1,00,000
Car Park 18.00% 27,000 1,50,000
Total Cost 3,88,656 23,50,600
GST 3,88,656
Total Unit Amount 27,39,256
Tax payable 3,88,656
Less: Input 2,32,161
Net Tax payable 1,56,495
- Tax payable undercomputed under workscontract services
- Under this category, valueof land should be excludedfrom the gross value. Thereshould be a properdocumentary evidence tosubstantiate the same.
- Rate of tax is 18% on theconstruction amount
- The tax payable is more byINR 1,06,584/- comparedto method I
Vishnu Daya & Co
Input Tax Credit –
GST ParticularsTax
RateAmount Amount
Effective
Cost
Cement, Ceramics, Bricks
etc 28% 15,283 54,583 54,583
Steel & others 18% 1,10,219 6,12,330 6,12,330
Sand & Jelly 5% 120 2,396 2,396
Labour charges 18% 60,721 3,37,338 3,37,338
Office Exp:
Admin Charges 18% 16,200 90,000 90,000
Salary - - 90,000 90,000
Finance Cost - - 1,20,000 1,20,000
Selling Cost 18% 29,618 1,64,542 1,64,542
Total 2,32,161 14,71,188 14,71,188
- Majority of the
construction materials are
grouped under 28% bracket
- Services are majorly
grouped under 18% bracket
- However, there is additional
cost benefit since excise
duty component and CST
component would be
available as credit
Vishnu Daya & Co
Comparison with Current
to GST Particulars Current GST Impact
Gross Tax Payable 2,03,403 2,82,072 -78,669
Total Taxes paid on purchases 2,67,610 2,32,161 35,449
Input Credit Taken 88,782 2,32,161 1,43,379
Net Tax Payable 1,14,621 49,911 64,710
Total Tax Cost to customer 3,82,231 2,82,072 1,00,159
- On the customer collection point ofview, there is an increase in the tax to becollected.
- On the procurement side, there is anincrease in the input availability as well.
- If construction service method followed,then there would be positive impact.
- If works contract entry followed, therewould be negative impact.
- The comparison is made in respect ofthe units which would be sold entirelyafter GST. In case of partially sold units,impact would be changed dependingupon the completion and procurementstatus
Vishnu Daya & Co
12% under GST
Particulars Current GST Impact
Gross Tax Payable 3,46,719 3,88,656 -41,937
Total Taxes paid on purchases 2,67,610 2,32,161 35,449
Input Credit Taken 1,85,296 2,32,161 1,43,379
Net Tax Payable 1,61,423 1,56,495 4,928
Total Tax Cost to customer 4,29,033 3,88,656 40,377
18% under GST
Advance paid Vs
Advance received
The supplier will be liable to GST on advance paid
irrespective of it’s purpose
Though the supplier can raise invoice for the advance paid,
credit thereon can be availed only after the receipt of
material. Hence it is cumbersome to have clear accounting
of such invoice
Vendor has to issue advance receipt voucher
If any advance is collected, tax thereon has to be paid
immediately
An advance receipt voucher to be prepared with prescribed
contents
If advance is refunded, advance refund voucher to be
prepared with prescribed contents
In case the advance is refunded, tax paid thereon has tobe claimed refund only.
Purchase return
Vishnu Daya & Co
• Raise sales invoice and charge GSTPurchase return of materials purchased before the GST on which either VAT or
excise or both transition credit was availed
• Vendor (supplier) has to raise credit note with invoice reference and date. The credit note has to be accounted and input credit should be reversed
Purchase return of material purchased after the GST but returned within 6
months to 18 months from the date of purchase
• Raise supply invoice on the vendor.Purchase return beyond the above period
Job work
Job work – definition:
any treatment or process undertaken by a
person on goods belonging to another
registered person and the expression “job
worker” shall be construed accordingly
Section 143 requires to follow the procedure
of obtaining the permission of
commissioner to send the goods for job
work
If procedure is not followed, GST may have
to be charged
Vishnu Daya & Co
Questions – If
procedure is not
followed
How to send same for job worker who is
URD?
Whether self e way bill can be used to
bring the material from URD job worker
to location?
Records to be maintained to send and
receive material from job worker
Vishnu Daya & Co
Switching over
from one
apartment to
another
It will be treated as return of supply which
is equal to sales return
If it happens within September of
previous year, it can be allowed as sales
deduction
If it happens after September of the
previous year, any tax paid in the previous
will not be allowed as tax adjustment
Credit note for the sales return should be
given
Vishnu Daya & Co
Questions Loss of GST paid
Should be reported as sales return inGST
New apartment booked should bereported as sales
GST may have to be paid on the newbooking
Any amount recovered for switchingover will be taxed as new stream ofservice
Vishnu Daya & Co
Cancellation of
apartment
Similar to switch over
Cancellation within September andbeyond September
If it happens within the permitted timelimit, GST adjustment can be made
If it happens beyond the permitted timelimit, there will be GST loss
When sold to others, it will not be animmovable property
When sold to others, tax paid earlier willnot be allowed as deduction
Vishnu Daya & Co
Sale by individual
to third party and
consenting party
by developer
In this case, the developer or owner
will only change the name of the
new buyer
The developer will get some
amount for agreeing such
arrangement
Vishnu Daya & Co
How it will impact
in GST
Since the original agreement itself
will give the liberty to register either
in the name of the party or any other
family members or others, it will not
have any impact
If any amount is charged for
consenting the deal, it will be liable
for GST in the hands of developer
Buy back
Works contract and construction services
have been declared as services
Any buyback of the works contract would be
held as “URD purchase” and hence it will be
liable for GST in the hands of buyer
In case of buy back, tax will suffer twice
Vishnu Daya & Co
Inter-state works
contract
Place of business
Location of the provider /
supplier of service
Location of the receiver
Place of supply in respect of
works contract or construction
service
Vishnu Daya & Co
Place of
Business
“fixed establishment” means a place (other thanthe registered place of business) which ischaracterised by a sufficient degree ofpermanence and suitable structure in terms ofhuman and technical resources to supplyservices, or to receive and use services for itsown needs;
“place of business” includes ––
a place from where the business is ordinarily carriedon, and includes a warehouse, a godown or any otherplace where a taxable person stores his goods,supplies or receives goods or services or both; or
a place where a taxable person maintains his books ofaccount; or
a place where a taxable person is engaged in businessthrough an agent, by whatever name called;
Vishnu Daya & Co
Location of
the Supplier
of Service
Where a supply is made from a place of businessfor which the registration has been obtained, thelocation of such place of business;
Where a supply is made from a place other thanthe place of business for which registration hasbeen obtained (a fixed establishment elsewhere),the location of such fixed establishment;
Where a supply is made from more than oneestablishment, whether the place of business orfixed establishment, the location of theestablishment most directly concerned with theprovisions of the supply; and
In absence of such places, the location of theusual place of residence of the supplier;
Vishnu Daya & Co
Location of
the receiver
of service
Where a supply is received at a place of business forwhich the registration has been obtained, thelocation of such place of business;
Where a supply is received at a place other than theplace of business for which registration has beenobtained (a fixed establishment elsewhere), thelocation of such fixed establishment;
Where a supply is received at more than oneestablishment, whether the place of business orfixed establishment, the location of theestablishment most directly concerned with thereceipt of the supply; and
In absence of such places, the location of the usualplace of residence of the recipient;
Vishnu Daya & Co
Place of
supply in case
of works
contract
Service directly in relation to an immovable property, including
services provided by architects, interior decorators, surveyors,
engineers and related experts or estate agents, any service provided by
way of grant of rights to use immovable property or for carrying out
or co-ordination of construction work;
Any services ancillary to the services referred above
Location at which the immovable property is located or intended to
be located.
If the location of the immovable property is located or intended to be
located outside India, the place of supply shall be the location of the
recipient
Where the immovable property is located in more than one State or
Union territory, the supply of services shall be treated as made in each
of the respective States or Union territories, in proportion to the value
for services separately collected or determined in terms of the contract
or agreement entered into in this regard or, in the absence of such
contract or agreement, on such other basis as may be prescribed.
Vishnu Daya & Co
Whether
registration is
required for inter-
state works
contract
If materials and services are sourced
from outside the state, it may not require
registration in the particular state.
If materials and services are sourced
locally and registration is not obtained,
that part of the credit will not be
available. Since location of supplier and
place of supply in the same state,
suppliers will charge CGST/ SGST
Vishnu Daya & Co
Other issues If recipient state requires the inward
way bill, then it is required to register
Movement of the goods from the site
office would be difficult
State authorities will claim that site office
is place of business as in that place
materials and services will be received
Movement of scrap or sale of scrap etc.,
would be difficult
Vishnu Daya & Co
High Sea Sale
High sea sale will be a taxable supply. Only IGSTwill be charged
If the buyer is a SEZ unit, tax need not becharged
Issues:
The department may dispute the value
Whenever the supply is made as high sea sale, itshould be removed from the scope of workscontract or composite supply
If a same person is given with two POS – high seasale and installation, then the rate of tax forinstallation will be equal to rate of tax applicablefor goods
Vishnu Daya & Co
Construction to
EOU, STPI and
SEZ
No exemption to EOU and STPI
Construction to SEZ is zero rated supplyand hence not taxable
On procurement and sub contracts, taxwill have to be paid
There may be exemption to subcontractors when the main contractor isexempt from GST.
If input accumulates on account ofconstruction to SEZ, refund can beclaimed
Vishnu Daya & Co
Government
Projects, Low
Cost Housing
and Single House
Government has withdrawn the exemption
to low cost housing and single house
If a labour contractor provides the pure
labour service for the construction of
individual house, he is not liable for CGST.
We have to see exemption under SGST
separately
Vishnu Daya & Co
Issues:
Project under construction. WIP may be taxed under GST
Tax clause with the Government or authorities
Precautions:
Raise the invoice to the extent of work completed before the
commencement of GST
Transition credits
Currently under COT under VAT
Currently under regular under VAT
Currently wholly sub contracted
Currently partly sub contracted
Service tax under abatement scheme (say
30%)
Service tax under actual scheme
Service tax under 40% scheme
Service tax under 70% scheme
Types of
transition
credits-
desired
Excise duty paid on materials in the form of stock and WIP
Excise
VAT on the materials in the form of stock on hand and WIP
VAT
Credit taken and available as balance in the service tax and VAT returns
Credit
Vishnu Daya & Co
What is the
provision for
works
contractors?
Works contractors paying the service tax
under notification number 26/2012
(30% on total value including land) alone
made eligible for transition credit
WIP is not covered and hence even
though WIP is service, it is not eligible
for transition credit
Separate legal provision has to be
provided for transition credit of SGST
part
Vishnu Daya & Co
Who will not get
transition credit?
Works contractors under 40% or 70% or
actual scheme.
Works contractors undertaking exempted
project
Vishnu Daya & Co
What is the way out?
Invoice
Invoice the WIP as per the current law
Steel
If you are purchasing the materials like cement, steel etc., source the same with excise invoice
Change
Change the sub contractors into regular dealer and avail input credit
Register
Register under central excise as dealer in the second week of June
File
File the dealer return and final return under existing VAT and service tax law
File
File the transition form within 30 days
COT
If you have sub contracted the work to a COT dealer, advise him to defer the invoice to GST regime
Vishnu Daya & Co
Transition issue Where service tax paid on the advances
received but Vat portion is not paid.
How to pay the GST?
Huge unsold inventory and currently
entire project is sub contracted to a COT
dealer
Vishnu Daya & Co
Tax Invoice
a) Name, address and GSTIN of the supplier;
b) A consecutive serial number, in one or multiple series, containing alphabets or numerals orspecial characters hyphen or dash and slash symbolised as “-” and “/” respectively, and anycombination thereof, unique for a financial year;
c) Date of its issue;
d) Name, address and GSTIN or UIN, if registered, of the recipient;
e) Name and address of the recipient and the address of delivery, along with the name of Stateand its code, if such recipient is un-registered and where the value of taxable supply is fiftythousand rupees or more;
f) HSN code of goods or Accounting Code of services;
g) Description of goods or services;
h) Quantity in case of goods and unit or Unique Quantity Code thereof;
i) Total value of supply of goods or services or both;
j) Taxable value of supply of goods or services or both taking into account discount orabatement, if any;
k) Rate of tax (central tax, State tax, integrated tax, Union territory tax or cess);
l) Amount of tax charged in respect of taxable goods or services (central tax, State tax,integrated tax, Union territory tax or cess);
m) Place of supply along with the name of State, in case of a supply in the course of inter-Statetrade or commerce;
n) Address of delivery where the same is different from the place of supply;
o) Whether the tax is payable on reverse charge basis; and
p) Signature or digital signature of the supplier or his authorized representative
Vishnu Daya & Co
Receipt
Voucher
a) name, address and GSTIN of the supplier;
b) a consecutive serial number not exceeding sixteen characters, in one or multiple
series, containing alphabets or numerals or special characters -hyphen or dash
and slash symbolised as “-” and “/”respectively, and any combination thereof,
unique for a financial year
c) date of its issue;
d) name, address and GSTIN or UIN, if registered, of the recipient;
e) description of goods or services;
f) amount of advance taken;
g) rate of tax (central tax, State tax, integrated tax, Union territory tax or cess);
h) amount of tax charged in respect of taxable goods or services (central tax,
State tax, integrated tax, Union territory tax or cess);
i) place of supply along with the name of State and its code, in case of a supply
in the course of inter-State trade or commerce;
j) whether the tax is payable on reverse charge basis; and
k) signature or digital signature of the supplier or his authorized representative:
Vishnu Daya & Co
Debit Note
and Credit
Note
a) the word “Revised Invoice”, wherever applicable, indicated prominently;
b) name, address and GSTIN of the supplier;
c) nature of the document;
d) a consecutive serial number not exceeding sixteen characters, in one or multiple
series, containing alphabets or numerals or special characters -hyphen or dash
and slash symbolised as “-” and “/”respectively,, and any combination thereof,
unique for a financial year; (e) date of issue of the document;
e) name, address and GSTIN or UIN, if registered, of the recipient;
f) name and address of the recipient and the address of delivery, along with the
name of State and its code, if such recipient is un-registered;
g) serial number and date of the corresponding tax invoice or, as the case may be,
bill of supply;
h) value of taxable supply of goods or services, rate of tax and the amount of the
tax credited or, as the case may be, debited to the recipient; and
i) signature or digital signature of the supplier or his authorized representative:
Vishnu Daya & Co
E-Way Bill
Mandatory for movement of goods if valueexceeds INR 50,000/-
Can be generated by supplier or transporter
Generate the e-way bill for all inwardsupplies from an unregistered person
Valid for 1, 3, 5, 10 or 15 days from the dateof generation depending upon the distancethe goods have to be transported
Cancellation within 24 hours
In case of multiple consignments –transporter to generate E-Way Bill
Vishnu Daya & Co
Vishnu Daya & Co.
VISHNU DAYA & CO.CHARTERED ACCOUNTANTS
CA Dayananda K
98450 25682
CA Vinayaka Hegde
99025 86492
Bangalore:
GF 7 & 3rd Floor, Karuna Complex, No. 337,
Sampige Road, Malleswaram, Bangalore-560003
Phone: +91-80-23312779
+91-80-23560633
Chennai:
1-C, 'Queens Court' 6/102, Monteieth Road,
Egmore, Chennai - 600 008
Phone: +91-044-28554447
Pune:
B-1 603, Kumar Prime Rose,
Near Eon IT Park,
Kharadi, Pune-411014