Circular No. 194/06/2023
This circular provides clarity on who must collect TCS under section 52 of the CGST Act when more than one e-commerce operator (ECO) participates in a single transaction, such as in the ONDC framework. It explains that when the buyer-side ECO collects payment but the seller-side ECO releases the final payment to the supplier, the seller-side ECO is responsible for collecting and depositing TCS and completing related compliances. If, however, the seller-side ECO is also the actual supplier, then the buyer-side ECO must collect TCS when making payment to that supplier.
The circular ensures that only the ECO making the final payout to the supplier bears the TCS obligation, avoiding duplication of compliance where multiple ECOs are involved.
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