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Greetings from Fundscoop Advisors!!

We must be aware that the Government has issued a Notification No 51/2018 CGST dated September 13, 2018, thereby enforcing the provisions under Section 52 of the Central Goods and Services Tax Act, 2017 (CGST Act') related to tax collection at source ('TCS') from October 1, 2018. Similar provisions also exist under the State GST law and Integrated Goods and Services Tax law.

Any business with respect to the services facilitated through its e-commerce platform, qualifies as an e-commerce operator ('ECO') as defined under the GST laws. Accordingly, those businesses should be committed towards undertaking TCS compliances once the said provisions become effective from October 1, 2018.

The applicability of TCS provisions would require changes in the payment mechanism, disclosure in GST returns, payment of tax, availment of credits etc.

In order to avoid any road blocks and keeping the rollout date on October 1, 2018 in mind, as a proactive approach, we are continuously studying to adapt to the process changes foreseen. We also expect your organization to take necessary steps ensuring preparedness to comply with TCS provisions.

As valued client, we expect your organization to take the necessary steps to have compliant systems and processes ensuring preparedness for the upcoming changes due to applicability of TCS related provisions, in order to avoid last minute glitches.

We have summarized key provisions related to TCS compliances and the high-level impact on the business, which needs to be acted upon on priority basis:


Thus, it is important to understand the changes which applicability of TCS provisions would bring and consequent requirement for change in the IT infrastructure, in order to ensure a smooth compliance of relevant legal provisions.

Our team will provide support and cooperation towards timely implementation of TCS provisions. We shall keep you posted on any further development in this regard.


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