Answer

GST

Purchases from unregistered suppliers by a composition dealer

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  1. Facts

    Generally no. Reverse charge on purchases from unregistered suppliers applies only to notified cases under Sec 9(4), not to all such purchases.

  2. Provisions and law

    • Sec 9(4), CGST Act 2017Notified classes of registered recipients pay tax under reverse charge on specified supplies from unregistered suppliers.
    • Sec 9(3), CGST Act 2017Tax on notified goods and services is paid by the recipient under reverse charge.
  3. Analysis

    Older articles say all unregistered purchases attract RCM for composition dealers, but that general rule does not apply now. Check the notified list, which covers certain cases like real estate promoters. Ordinary stock bought from small unregistered vendors does not attract RCM. Keep purchase records anyway.

  4. Conclusion

    1. Check whether your purchase falls in a notified Sec 9(4) case.
    2. If not, no RCM is payable on it.
    3. Record all purchases for GSTR-4.
    4. Recheck the list when notifications change.

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