Accounting & Compliance · Kolte Enterprises← Back to Ledger Logic
Truck-owners, transporters, fleet operators and freight contractors — RCM versus FCM under GST, Section 44AE presumptive scheme, the 194C(6) declaration and e-way bill discipline.
A GTA owning fewer than 10 vehicles can receive freight without a single rupee of TDS being deducted — provided one piece of paper, signed once a year, sits with every customer. The Sec 194C(6) declaration is what stands between you and a 1-2% TDS bite on every freight bill.
Source: Section 194C(6), Income Tax Act 1961, read with the prescribed declaration format under Rule 31A.A Goods Transport Agency, defined in Notification 11/2017-CT(R), is anyone who transports goods by road and issues a consignment note. The consignment note is what separates a GTA from a casual truck-owner. Once you are a GTA, you choose every year between 5% RCM (no ITC, paid by the recipient), 5% FCM (no ITC, paid by you), or 12% FCM (with ITC, paid by you). The choice is made by 31 March in Annexure V for the upcoming FY (Notification 03/2022-CT(R)).
On the income-tax side, transporters get the most generous presumptive scheme in the Act. Section 44AE deems profit at Rs 7,500 per heavy goods vehicle per month, regardless of the freight you actually earned. Combined with the 194C(6) NIL-TDS option for small fleets, this sector has the cleanest year-end if the paperwork is in place.
The Income Tax Act 1961 — and the new Income Tax Act 2025 effective 1 April 2026 — keep the same pillars: pay advance tax on time, file an accurate return, and stay clean on cash. The KPIs below are the ones an audit officer pulls up first if your file lands on a scrutiny desk.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| Sec 44AE — Presumptive scheme | Profit deemed at Rs 1,000 per ton GVW per month for heavy goods vehicles (above 12 MT) and Rs 7,500 per vehicle per month for others. Available only if you owned fewer than 10 vehicles at any point during the FY. | ITR by 31 Jul 2027 | Sec 44AE |
| Tax audit u/s 44AB | Mandatory if (a) you opted out of 44AE and turnover crosses Rs 1 crore, or (b) you owned more than 10 vehicles, taking 44AE off the table. | 30 Sep 2027 | Sec 44AB |
| Advance tax | 44AE assessees can pay 100% by 15 March (Sec 211(1)(b)). | Quarterly / 15 Mar | Sec 211 |
| Cash payment to GTA — 40A(3) | Higher Rs 35,000 limit (vs Rs 10,000 for others) under the second proviso to 40A(3) for goods carriage payments. | Continuous | Sec 40A(3) Proviso |
| ITR filing | ITR-3 / ITR-4 SUGAM (44AE) / ITR-5 (firm). | 31 Jul / 31 Oct 2027 | Sec 139(1) |
TDS payments are due by the 7th of the next month (March is 30 April), and quarterly Form 26Q or 27EQ returns drive Form 16 / 16A on TRACES. Late filing of the return alone costs Rs 200 per day under Sec 234E.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| 194C — TDS on freight (deductee side) | Customer deducts 1% / 2%. NIL TDS if (a) you own fewer than 10 goods carriages, (b) PAN is furnished, (c) the prescribed declaration is filed with the deductor. | On every invoice | Sec 194C(6) |
| 194C — Payments to sub-transporter | 1% / 2% if you sub-let part of a load to a truck owner who has more than 10 vehicles. | 7th of next month | Sec 194C |
| 194Q — Diesel, tyres, spares | 0.1% on purchases above Rs 50 lakh from one supplier (turnover above Rs 10 crore). | 7th of next month | Sec 194Q |
| 194I — Office or parking yard rent | 10% on rent above Rs 2.4 lakh in the FY. | 7th of next month | Sec 194I |
| Quarterly Form 26Q | File on time. Verify the deductor's 26AS shows your freight under 194C with the correct PAN. | 31 Jul, 31 Oct, 31 Jan, 31 May | Rule 31A |
GST is the most data-rich compliance regime — every invoice you raise and every invoice you receive sits on the network. Use GSTR-2B, not 2A, as your reconciliation base from FY 2022-23 onwards.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| RCM (default) | 5% paid by the recipient (no ITC for the GTA, full ITC for the body corporate, factory, partnership or society receiving the service). | Continuous | Notification 13/2017-CT(R) Sl. 1 |
| FCM at 5% (no ITC) — optional | GTA can opt to pay 5% itself but cannot claim ITC. Election is made in Annexure V by 31 March for the next FY. | Continuous | Notification 03/2022-CT(R) |
| FCM at 12% (with ITC) — optional | GTA can opt to pay 12% with full ITC of inputs (tyres, spares, fuel). Same Annexure V election. | Continuous | Notification 03/2022-CT(R) |
| Always-Nil exemptions | Transport of agricultural produce, milk, salt, food grains, organic manure, defence goods. Or single consignment freight of Rs 1,500 or less. Or single consignee freight of Rs 750 or less. | Continuous | Notification 12/2017-CT(R) Sl. 21 |
| Consignment note | Pre-printed and serially numbered, capturing consignee, consignor, description, weight and freight rate. Without this, you are a hire-of-vehicle service, not a GTA. | Per trip | Notification 11/2017-CT(R) Para 2(ze) |
| E-way bill | Required for movement above Rs 50,000. Transporter ID (TRANSIN) must be entered when the consignor does not generate. | Pre-movement | Rule 138 |
| GSTR-1 / 3B | Monthly, or QRMP if turnover at or below Rs 5 crore. FCM GTAs file regular returns. RCM-only GTAs still file GSTR-1 with reverse-charge marking. | 11th / 20th | Sec 37 / 39 |
| GSTR-9 / 9C | Annual return plus reconciliation if turnover above Rs 5 crore. | 31 Dec 2027 | Sec 44 |
Profession Tax is a state levy run by the Maharashtra Goods & Services Tax Department. There are two registrations and most businesses need both — one for the owner, one for the staff.
| Registration | Who needs it / what you pay | Due date | Source |
|---|---|---|---|
| PTEC (Enrolment) |
For the proprietor, partner, director, LLP or company. Flat Rs 2,500 per year for most non-salaried professions and businesses. | 30 June | MahaGST PT Act 1975 |
| PTRC (Registration) |
For employers paying salary above Rs 7,500 p.m. (male) or Rs 25,000 p.m. (female). Slabs: Rs 175 p.m. for Rs 7,501–10,000 (male); Rs 200 p.m. plus Rs 300 in February if salary exceeds Rs 10,000. Annual ceiling Rs 2,500 per employee. | Last day of the next month | MahaGST PT Rules |
If your previous-year PT liability crossed Rs 1 lakh, file PTRC monthly. Below that, annual is fine. Returns go on mahagst.gov.in. Late filing costs Rs 1,000 per return plus 1.25% interest a month.
Section 44AA of the Income Tax Act and Section 35 (read with Rule 56) of the CGST Act set the bookkeeping baseline. For most non-professional businesses, books are required if income is above Rs 2.5 lakh or turnover above Rs 25 lakh in any of the three preceding years.
One folder per FY, with sub-folders: sales invoices, purchase invoices, bank statements, GST returns, TDS challans and returns, ROC filings, expense bills, statutory dues, loan documents, fixed asset purchases. Scan everything within 30 days. Scanned PDFs are accepted as books under Rule 6F(5) and CGST Rule 56(15).
The four mistakes our team sees most often when we take over books from another firm:
Without a CN you are providing hire of goods vehicle (SAC 9966), taxable at 18% RCM under a different head, with restricted ITC for the recipient. Use serially-numbered CNs even for short trips.
If you do not file Annexure V by 31 March, your GST option for the next FY locks at the previous year's option by default. You lose the ITC route if you wanted to switch to 12% FCM.
Even one day with the 11th vehicle on books takes you out of 44AE for the entire FY. Time the purchase or sale of trucks around 1 April.
If you give a sub-truck owner who has more than 10 vehicles a job, 194C TDS applies on the freight you pay him, even if your customer has already deducted on the parent invoice.
| Month | Compliance milestones |
|---|---|
| April | TDS payment for March (30 Apr); GSTR-1 / 3B for March; PT employee deduction. |
| May | Q4 TDS return Form 26Q (31 May); Form 16A; SFT-005 / 61A (31 May). |
| June | Form 16 to employees (15 Jun); Q1 advance tax (15 Jun); PTEC payment (30 Jun). |
| July | Q1 TDS return (31 Jul); ITR for non-audit cases (31 Jul); QRMP option last month. |
| August | Routine GSTR-1 / 3B; e-invoice review. |
| September | Tax audit report u/s 44AB (30 Sep); Form 10B / 10BB (30 Sep) for trusts; Q2 advance tax (15 Sep). |
| October | Q2 TDS return (31 Oct); ITR for audit cases (31 Oct); GSTR-9 prep starts. |
| November | ITR for transfer-pricing cases (30 Nov). |
| December | Q3 advance tax (15 Dec); GSTR-9 / 9C filing (31 Dec). |
| January | Q3 TDS return (31 Jan); books reconciliation for FY closing. |
| February | Stock-take preparation; PT special slab (Rs 300 in Feb). |
| March | Q4 advance tax (15 Mar); Annexure V for GTAs (31 Mar); books closure; year-end TDS. |
Talk to our compliance team. We work with contractors, traders, hotels, hospitals, transporters and manufacturers across Maharashtra.
Book a Free ConsultationLedger Logic advises businesses across Bhusawal, Mumbai and Pune on Income Tax, TDS, GST, Profession Tax and statutory bookkeeping. The points above are general guidance — please consult your CA before acting on a specific transaction.