Harun Raaj & AssociatesHarun Raaj & Associates
Indirect Tax Services

GST TCS — E-Commerce Operator Compliance

GST TCS E-Commerce

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Regulatory Framework

Tax Collection at Source (TCS) for e-commerce operators is governed by Section 52 of the CGST Act, 2017. Every e-commerce operator (ECO) — other than an agent — through which suppliers make taxable supplies of goods or services must collect TCS on the net value of taxable supplies made through it, where the consideration for such supplies is collected by the operator.

The applicable rate was reduced from 1% (0.5% CGST + 0.5% SGST for intra-state supplies, or 1% IGST for inter-state supplies) to 0.5% (0.25% CGST + 0.25% SGST, or 0.5% IGST) with effect from 10.07.2024, pursuant to Notification No. 15/2024-Central Tax. "Net value of taxable supplies" means the aggregate value of taxable supplies of goods or services made through the operator by all registered persons, reduced by the aggregate value of taxable supplies returned during the month.

Registration and compliance consequences: suppliers making supplies through an e-commerce operator that is required to collect TCS must obtain GST registration under Section 24(ix), without the benefit of the turnover-based threshold exemption, except for specified categories of suppliers (e.g., certain small suppliers of services, and — per Notification No. 34/2023-Central Tax and related amendments — small goods suppliers using a special composition-linked exemption) permitted to supply through e-commerce operators without mandatory registration, subject to conditions. The operator must deposit TCS collected to the Government by the 10th of the month following the month of collection, and must file a monthly return in FORM GSTR-8. The supplier can claim credit of the TCS so collected in their electronic cash ledger upon the operator's GSTR-8 being filed, based on the details auto-populated on the common portal.

Overview

GST TCS is the tax collected at source that e-commerce operators must collect on the supplies made through their platforms. Under Section 52 of the CGST Act 2017, an e-commerce operator must collect TCS at the notified rate on the net value of the taxable supplies made through it, remit it to the government, report it in the GSTR-8, and issue the statement to the sellers so they can claim the credit. The collection is a layer of compliance that sits on top of the seller's own GST registration and returns.

The TCS is the tax that the platform collects on the seller's behalf. Every sale through the platform carries the collection, the GSTR-8 reports it, and the seller's credit ledger receives the TCS amount — the mechanism that keeps the seller's tax collected at source reconciled with the tax they pay. For the platform, the compliance is a system: the collection rate, the remittance, the GSTR-8, and the statements to the sellers, all under Section 52.

The cost of a broken TCS cycle is the mismatch: the TCS collected but not remitted or reported becomes a demand with interest under the Act, and the sellers whose statements are wrong carry a credit position they cannot reconcile. The e-commerce sector is one of the most audited positions in GST — the TCS trail is the record the department reads.

This service is for e-commerce operators and marketplace sellers. For the operators, we set up the TCS collection under Section 52, manage the remittance and the GSTR-8, and issue the seller statements; for the sellers, we reconcile the TCS shown in the GSTR-2B with the platform statements and claim the credit correctly in the returns.

How It Works

  1. 1

    TCS Obligation Mapping

    We map the platform's supplies and the TCS obligation under Section 52.

    Harun Raaj & Associates does this3-5 days
  2. 2

    Collection & Remittance Setup

    We set up the TCS computation, the collection and the remittance process.

    Harun Raaj & Associates does this1 week
  3. 3

    GSTR-8 Filing

    We prepare and file the GSTR-8 with the TCS collected.

    Harun Raaj & Associates does thisMonthly
  4. 4

    Seller Statement Issuance

    We issue the TCS statements to the sellers for their credit claims.

    Harun Raaj & Associates does thisMonthly
  5. 5

    Seller Credit Reconciliation

    For sellers, we reconcile the TCS in the GSTR-2B with the platform statements.

    Harun Raaj & Associates does thisMonthly

Frequently Asked Questions

Who is an Electronic Commerce Operator (ECO) and what is the TCS obligation?
Section 52 CGST Act: an ECO is a person who owns/operates a digital or electronic facility for supply of goods or services. TCS applies to: every ECO making net taxable supplies through its platform (i.e., where the ECO is not itself the supplier — third-party marketplace model). Rate: 1% of the net value of taxable supplies (0.5% CGST + 0.5% SGST/UTGST, or 1% IGST for inter-state). Deducted at the time of actual payment to the supplier.
What is GSTR-8 and when must an ECO file it?
GSTR-8 is the TCS return for Electronic Commerce Operators — filed monthly by the 10th of the following month. It reports: TCS collected from each supplier (GSTIN-wise), the net taxable value, and TCS deposited. The supplier's TCS credit appears in their electronic cash ledger automatically on filing of GSTR-8. The supplier can use this credit to set off their GST liability. ECOs must register for GST mandatorily under Section 24(x), regardless of turnover.
Can a supplier selling on an ECO platform claim the TCS deducted?
Yes — the TCS deducted by the ECO (from the supplier's receivable) is credited to the supplier's electronic cash ledger once the ECO files GSTR-8 for the relevant month. The supplier claims this as a credit against their own GSTR-3B liability. If the credit exceeds the liability, the supplier can claim a refund under Section 54. GSTR-8 must be filed before the supplier's GSTR-3B for the same period to ensure the credit is available.
What supplies are exempt from ECO TCS?
TCS under Section 52 is not deducted on: (a) supplies of services notified under Section 9(5) — where the ECO is itself the supplier and pays GST as if it were the supplier (e.g., cab services via app, hotel accommodation booked via app); (b) supplies of exempt goods and services; (c) supplies where the ECO is also the seller (own account supplies — not marketplace model). For Section 9(5) supplies, the ECO pays the full GST — TCS does not apply as the supplier-ECO distinction collapses.
How does GST apply to food delivery aggregators like Swiggy/Zomato?
Section 9(5) notification (Notification 17/2021-CT): restaurant services provided through ECO platforms (food delivery apps) — the ECO (Swiggy/Zomato) is liable to pay GST at 5% as if it were the supplier, regardless of whether the restaurant is GST-registered or not. The restaurant is not required to pay GST on sales through these platforms — the platform pays. This shifts GST compliance from thousands of small restaurants to a handful of large aggregators.

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