Mr. Muttswami, an electronics dealer registered in Bangalore, Karnataka hired M/s Parivahan Logistics, an unregistered Good Transport Agency (GTA),…

(a) Supply of services by a Goods Transport Agency (GTA) in respect of transportation of goods by road to any person registered under the GST is taxable under reverse charge mechanism in terms of section 9 (3) of the CGST Act, 2017. Thus, Mr. Muttswami, being the registered recipient is liable to pay tax under reverse charge mechanism in respect of services received from unregistered GTA. (i) Person liable to issue the tax invoice As per section 31 (3) (f) of the CGST Act, 2017, a registered person who is liable to pay tax under reverse charge mechanism under section 9 (3) / 9 (4) , shall within the period as may be prescribed issue an invoice in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both. Since, M/s Parivahan Logistics is an unregistered GTA, Mr. Muttswami, being liable to pay the tax under reverse charge mechanism under section 9 (3) is required to issue the tax invoice. (ii) Time limit for issuance of the tax invoice Rule 47A of the CGST Rules, 2017 provides that where an invoice referred to in rule 46 is required to be issued under section 31 (3) (f) by a registered person, who is liable to pay tax under section 9 (3) / 9 (4) , he shall issue the said invoice within a period of 30 days from the date of receipt of the said supply of goods and/or services, as the case may be. Thus, Mr. Muttswami is required to issue a tax invoice till 3rd February (i.e. within 30 days of receipt of services). (iii) Time of supply of transportation services supplied by GTA. As per section 13 (3) of the CGST Act, 2017, in case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earlier of the following dates, namely:- (a) the date of payment as entered in the books of account of the recipient or the date on which the payment is debited in his bank account, whichever is earlier; or (b) the date immediately following sixty days from the date of issue of invoice or any other document, by whatever name called, in lieu thereof by the supplier, in cases where invoice is required to be issued by the supplier, or (c) the date of issue of invoice by the recipient, in cases where invoice is to be issued by the recipient. Since, in this case the reverse charge mechanism is applicable on receipt of services provided by GTA and invoice is issued by recipient, time of supply would be earliest of the following date: (a) Date of payment i.e. 4th January (b) The date of issue of invoice by the recipient i.e. 3rd February. So, the time of supply in this case will be 4th January.