GST on Real Estate Maintenance Charges: Return, ITC and Notice Checklist
Housing society maintenance looks simple until the ₹7,500 per month per member exemption, aggregate turnover threshold and ITC questions collide. RWAs and commercial property managers need a clear monthly GST working.
Use the GST Refund Route and RFD-01 Checklist to apply these points to your figures or facts.
The ₹7,500 per month per member rule
CBIC Circular 109/28/2019-GST clarifies that services by an RWA to its own members by way of reimbursement of charges or share of contribution up to ₹7,500 per month per member for common use of members in a housing society or residential complex are exempt. The circular also explains registration threshold and how the ceiling is applied.
For the connected rule, example or next step, see GST on Freight, GTA and Transport Charges: Return, ITC and Notice Checklist.
RWA decision table
| Situation | GST result to check | Evidence |
|---|---|---|
| Monthly maintenance up to ₹7,500 per member | Exemption may apply if other conditions are met. | Member ledger and monthly invoices. |
| Charges exceed ₹7,500 per member | Circular clarifies exemption is not available where charges exceed limit. | Invoice calculation and tax working. |
| RWA aggregate turnover up to ₹20 lakh | Circular says registration not required even if member charge exceeds ₹7,500. | Annual turnover working. |
| Owner has two flats | Ceiling applied separately per residential apartment/member relationship as clarified. | Flat-wise member ledger. |
For the connected rule, example or next step, see GST on Employee Recoveries and Notice Pay: Return, ITC and Notice Checklist.
ITC position for taxable RWA
The circular clarifies that RWAs are entitled to ITC of GST paid on capital goods, goods and input services used for making taxable supplies to members where charges exceed the exemption limit, subject to normal law. Maintain supplier invoices and inward register.
Common mistakes
- Applying ₹7,500 as a deduction instead of checking exemption condition.
- Forgetting aggregate turnover registration threshold.
- Mixing residential member charges with commercial/common facility income.
- No flat-wise/member-wise calculation.
Official References Used
This draft uses official GST law, rules, GST Council, CBIC/GST portal and government-source material only. Before publishing, re-check whether any notification, circular, rule text or portal workflow has changed after the draft date.
- CBIC Circular 109/28/2019-GST — RWA maintenance charges
- CBIC Tax Information: CGST Section 16 — input tax credit eligibility
- CBIC Tax Information: CGST Rule 36 — ITC documents
- CBIC Tax Information: CGST Section 22 — registration threshold
- CBIC Tax Information: CGST Section 31 — tax invoice requirements
For the connected rule, example or next step, see Under-Construction Property GST: Invoice and Rate Evidence Checklist.
Frequently Asked Questions
Source and review trail
Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.
- Primary category
- GST & Indirect Tax
- Official starting point
- www.gst.gov.in
Page source links
- CBIC Circular 109/28/2019-GST — RWA maintenance charges
- CBIC Tax Information: CGST Section 16 — input tax credit eligibility
- CBIC Tax Information: CGST Section 22 — registration threshold
- CBIC Tax Information: CGST Section 31 — tax invoice requirements
- GST Council — Central GST Act, Rules, notifications and circulars
- GST Council CGST circulars