Module 7: GST for E-Commerce Operators and Aggregators – Advance GST Course
🛒 Who is an E-Commerce Operator under GST?
As per Section 2(45) of the CGST Act, E-Commerce Operator (ECO) means any person who owns, operates, or manages a digital or electronic facility or platform for electronic commerce.
Examples:
- Marketplaces: Amazon, Flipkart, Meesho
- Service Aggregators: Swiggy, Ola, UrbanClap
- Travel Portals: MakeMyTrip, Goibibo
💡 GST Registration for E-Commerce Operators
Under GST, registration is mandatory for e-commerce operators regardless of turnover, as per Section 24 of the CGST Act.
Requirements:
- Operators must register in every state where they facilitate supplies.
- Sellers on e-commerce platforms also need GST registration, except when specifically exempt (e.g., certain service providers under threshold limits).
📌 Exemption: Suppliers of services through ECOs (like cab drivers or food delivery partners) may be exempt if turnover is below ₹20 lakh/₹10 lakh, but ECO is still responsible for TCS.
💰 Tax Collection at Source (TCS) under GST
E-commerce operators are required to collect TCS at the time of making payment to suppliers.
TCS Rates:
- 1% (0.5% CGST + 0.5% SGST) for intra-state supplies
- 1% IGST for inter-state supplies
When to Deduct:
- When payment is made to suppliers for supplies made through the ECO platform
Example:
If a seller earns ₹1,00,000 from sales via Amazon (intra-state), Amazon will deduct ₹1,000 as TCS and pay the seller ₹99,000.
🧾 TCS Return Filing: Form GSTR-8
E-commerce operators must file GSTR-8 monthly to report:
- Details of outward supplies made by sellers
- Amount of TCS collected
- GSTIN of suppliers
Due Date:
10th of the following month
📌 The TCS amount gets reflected in the seller’s electronic cash ledger and can be used to offset GST liability.
📋 Responsibilities of E-Commerce Operators
| Responsibility | Description |
|---|---|
| Mandatory Registration | Required in each state where supplies are facilitated |
| TCS Deduction & Deposit | Collect TCS and deposit by 10th of next month |
| Filing GSTR-8 | Report seller-wise TCS and supplies |
| Record Keeping | Maintain supply-wise, seller-wise transaction data |
| Assisting in Tax Recovery | ECOs may be held responsible for GST recovery in certain cases (Section 9(5)) |
🧠 GST under Section 9(5) for Specific Aggregators
In certain notified services, the ECO becomes liable to pay GST instead of the actual service provider.
Applicable Services:
- Transportation of passengers (e.g., Ola, Uber)
- Accommodation services via unregistered entities (e.g., Oyo)
- Housekeeping services (e.g., UrbanClap)
📌 In such cases, ECO must pay GST even if the actual service provider is unregistered.
⚠️ Challenges Faced by ECOs in GST Compliance
| Challenge | Explanation |
|---|---|
| Multi-state registration complexity | Each state requires separate GSTIN |
| Data reconciliation | Matching seller records, GSTR-8, and payment data |
| Frequent regulatory changes | Updates in 9(5) notifications or threshold exemptions |
| Refund claims of excess TCS | Requires precision in TCS deduction and seller mapping |
| Seller compliance tracking | Onboarding non-compliant sellers can lead to penalties |
🆕 Recent Updates (FY 2024–25)
- Auto-population of TCS in GSTR-2B for sellers from GSTR-8
- Tighter scrutiny on TCS returns and mismatch resolution
- Increased focus on platform-level responsibility under 9(5)
- Introduction of dashboard reconciliation tools for large ECOs
📝 Final Thoughts
The e-commerce sector is under increased GST surveillance, and ECOs must stay compliant with TCS, GSTR-8 filings, and registration norms. Missteps in reporting or reconciliation can lead to hefty penalties and delays in fund disbursements to sellers.
Proper system integration, expert advisory, and regular audits are key to staying GST-compliant in the digital marketplace.
📣 Need Help with E-Commerce GST Compliance?
At Verotus Finlegal Solutions LLP, we specialize in:
- GSTR-8 filing & automation
- TCS reconciliation & advisory
- GST registration across multiple states
- Section 9(5) compliance solutions
- GST health checks for marketplace aggregators
📍 Kolhapur, Maharashtra
🌐 www.verotusllp.com
📞 +91-7066336680
