Section 52 – Tax Collection at Source (TCS)
Section 52 of CGST Act, 2017 – Tax Collection at Source (TCS)
Updated on: February 2026 (as applicable till date)
Prepared by: Yours Tax Consultant
1. Scope and Objective of Section 52
Section 52 provides for Tax Collection at Source (TCS) under GST, applicable exclusively to Electronic Commerce Operators (ECOs).
The objective of GST-TCS is to:
- Track supplies made through e-commerce platforms
- Ensure tax compliance by online sellers
- Create a digital audit trail of transactions
2. Statutory Provision – Section 52(1)
An electronic commerce operator, not being an agent, shall collect tax at source at such rate not exceeding 1%, as may be notified, of the net value of taxable supplies made through it by other suppliers, where the consideration is collected by the operator.
3. Who is an Electronic Commerce Operator (ECO)?
An Electronic Commerce Operator is a person who:
- Owns, operates or manages a digital platform
- Facilitates supply of goods or services
- Collects consideration on behalf of suppliers
Examples include online marketplaces and delivery platforms.
4. Rate of TCS under GST
TCS is collected at:
- 0.5% CGST + 0.5% SGST, or
- 1% IGST for inter-State supplies
The rate is applied on the net taxable value (excluding GST).
5. Meaning of Net Value of Taxable Supplies
Net value of taxable supplies means:
- Aggregate value of taxable supplies made through ECO
- Less: value of taxable supplies returned to suppliers
Supplies on which the operator is liable to pay tax under Section 9(5) are excluded.
6. Time Limit for Deposit of TCS – Section 52(3)
The TCS collected shall be:
- Paid to the Government within 10 days after the end of the month in which it is collected
Delay attracts:
- Interest under Section 50
- Late fee under Section 47
7. TCS Return – Section 52(4)
Every electronic commerce operator shall:
- File a monthly statement in FORM GSTR-8
This statement contains:
- Details of supplies made through the platform
- Amount of TCS collected
8. Credit of TCS to Supplier – Section 52(7)
The amount collected as TCS:
- Is credited to the electronic cash ledger of the supplier
- Can be used for payment of tax, interest or penalty
Thus, GST-TCS is not a tax cost to the supplier.
9. Matching and Rectification – Section 52(8) to 52(10)
Details furnished by the ECO are:
- Matched with supplier’s outward supply details
Any mismatch:
- Is communicated to both parties
- Must be rectified in subsequent returns
Unrectified discrepancies may be added to supplier’s liability.
10. Annual Statement – Section 52(5)
Every ECO shall:
- Furnish an annual statement by 31st December following the end of the financial year
11. Section 52 Read with CGST Rules
Section 52 must be read with:
12. Common Practical Issues
- Incorrect computation of net taxable value
- Delay in filing GSTR-8
- TCS credit not reflecting in supplier ledger
- Mismatch between GSTR-1 and GSTR-8
13. Related Provisions
- Section 49 – Payment and electronic ledgers
- Section 50 – Interest
- Section 47 – Late fee
- Section 9(5) – Tax liability of ECO
14. Professional Insight
GST-TCS is a data-tracking mechanism, not a revenue tool. Accuracy in GSTR-8 is critical, as mismatches directly increase supplier liability.
Disclaimer: This article is prepared based on the CGST Act, CGST Rules, notifications and prevailing legal position as applicable till date. Rates, procedures and compliance requirements are subject to Government notification and amendment.
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