Answer

GST

CMP-08 when RCM exists but no sales

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  1. Facts

    No. If you had a reverse charge liability, the CMP-08 is not nil. You must file on the portal and pay the RCM tax.

  2. Provisions and law

    • Sec 9(3), CGST Act 2017Tax on notified goods and services is paid by the recipient under reverse charge.
    • Rule 62, CGST Rules 2017A composition taxpayer files CMP-08 by the 18th of the month after each quarter and GSTR-4 by 30 June after the year (Notification 12/2024-CT).
  3. Analysis

    Nil filing by SMS is only when both outward supplies and RCM inward supplies are zero. Declare the advocate fee in the inward supplies row and pay 18 percent RCM, for example ₹1,800 on ₹10,000. Filing nil wrongly leads to short payment, interest and later notices.

  4. Conclusion

    1. Check RCM liabilities for the quarter.
    2. If any, file CMP-08 on the portal.
    3. Enter the RCM value and tax.
    4. Pay in cash and file.

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