How to Report Sales Through E‑Commerce Operators in GSTR‑1: A Complete Guide

 

📌 Introduction: Why GST Reporting via E-Commerce Matters

In India’s rapidly growing digital economy, e-commerce platforms like Amazon, Flipkart, Zomato, Swiggy, Ola, and Urban Company have become dominant marketplaces. While these platforms empower even the smallest sellers to reach a national audience, they also introduce unique complexities under the Goods and Services Tax (GST) regime.

Why? Because when you sell through an E-Commerce Operator (ECO), the question of who is liable to pay GST, who issues the invoice, who collects TCS, and how it is reported in returns like GSTR-1 and GSTR-3B becomes nuanced.

Recent changes to GST returns, including the introduction of Tables 14 and 15 in GSTR-1, reflect the government’s push for transparency and better classification of e-commerce transactions.

This blog gives a comprehensive breakdown of:

ü  What constitutes a "sale through ECO"

ü  GST provisions that apply (Section 9(5) & Section 52)

ü  Return filing responsibilities of both suppliers and platforms

ü  New GSTR-1 tables and how to use them

ü  Practical implications and mistakes to avoid

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🧾 Who Is an E-Commerce Operator (ECO)?

As per GST law, an E-Commerce Operator is any person who owns, operates, or manages a digital platform that facilitates supply of goods or services.

This includes:

ü  Marketplaces like Amazon, Flipkart

ü  Food delivery apps like Zomato, Swiggy

ü  Ride-hailing services like Ola, Uber

ü  Local services platforms like UrbanClap

ECOs enable suppliers to connect with customers — but depending on what is sold and how, GST law may treat the ECO or the supplier as the tax-liable person.

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⚖️ Section 52: Tax Collected at Source (TCS)

When a registered supplier sells goods/services through an ECO, the ECO is mandated under Section 52 of the CGST Act to collect tax at source (TCS).

ü  Rate: 1% (0.5% CGST + 0.5% SGST or 1% IGST)

ü  Applies to: All e-commerce sales except those covered by Section 9(5)

ü  Purpose: Trace transactions and prevent tax evasion

ü  Reporting: ECO files GSTR-8 monthly to report TCS

The supplier can claim the TCS as credit in their electronic cash ledger while filing returns.

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⚠️ Section 9(5): Reverse Charge Liability of ECO

This is a special provision where, for certain notified services, the ECO is deemed to be the supplier even though it is only facilitating the supply.

🔍 Notified Services under Section 9(5):

1. Passenger transport services (e.g., Uber, Ola)
2. Restaurant services (e.g., Zomato, Swiggy — excluding those with own kitchens)
3. Housekeeping services (when provided by unregistered persons)
4. Hotel accommodation under certain conditions

🔄 Implication:

ü  The ECO must pay GST on these services, not the actual service provider.

ü  ECO must not use ITC for this payment — often made in cash.

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📊 New GSTR-1 Tables: Table 14 & Table 15

To enable structured reporting of ECO transactions, the GSTN introduced new tables from January 2024:

📘 Table 14 – Supplies through ECO (TCS under Section 52)

Applicable only to suppliers who:

ü  Sell goods/services through an ECO

ü  Are not covered under Section 9(5)

ü  Are responsible for paying GST themselves

Breakup:

ü  14(a) – Supplies through ECO (TCS collected)

ü  14(b) – Supplies through ECO where GST liability falls on ECO (auto-filled)

🧾 Suppliers report these sales here, in addition to B2B/B2C tables.

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📘 Table 15 – Supplies under Section 9(5)

Applicable only to ECOs, not suppliers.

ECOs report services under 9(5) that they are liable to pay GST on — including:

ü  Total taxable value

ü  Whether the supplier/recipient is registered or unregistered

These values also feed into GSTR-3B → Table 3.1.1(i) (newly added).

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🧮 Reporting Flow: Supplier vs. ECO

Scenario	Who Reports in GSTR-1	Who Pays GST	Table Used
Zomato delivers food (Restaurant is supplier)	Zomato (ECO)	Zomato	Table 15
Amazon seller sells mobile phone	Supplier	Supplier	Table 14(a)
Ola ride booked by customer	Ola	Ola	Table 15
UrbanClap cleaner booked via app	UrbanClap (if cleaner unregistered)	UrbanClap	Table 15

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🔁 GSTR-3B Reporting (Post-Jan 2024)

To complement the changes in GSTR-1, Table 3.1.1 was introduced in GSTR-3B:

ü  3.1.1(i): Supplies under Section 9(5) – reported by ECO

ü  3.1.1(ii): Supplies through ECO (TCS model) – reported by supplier

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🧩 Key Challenges for Businesses

1. Wrong Reporting Table
   Suppliers often wrongly report ECO sales in general B2C/B2B tables instead of Table 14.
2. TCS Credit Not Claimed
   If a supplier forgets to claim TCS collected by ECO, it leads to reconciliation mismatches.
3. Mismatch Between ECO and Supplier Data
   Tax officers can issue notices if GSTR-8 (ECO) data doesn’t match GSTR-1 (supplier) data.
4. Uncertainty About 9(5) Applicability
   Especially for hybrid services or aggregator models, suppliers may be unsure if 9(5) applies.
5. Cash Flow Issues
   TCS reduces immediate cash inflow to suppliers, impacting working capital.

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🧠 Best Practices for GST Compliance

✅ Identify your supply type: Is it a notified service under 9(5) or general e-commerce sale?

✅ Understand liability: Who pays GST? Who collects TCS? Who issues invoice?

✅ Use updated ERP/accounting software: It must support GSTR-1 Table 14 & 15 reporting.

✅ Reconcile monthly: Match ECO dashboard (e.g., Amazon Seller Central, Zomato Partner reports) with GSTR-1/GSTR-3B filings.

✅ Maintain documentation: Contracts, tax invoices, TCS reports, and platform statements — especially for audit readiness.

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📣 Final Takeaway

GST compliance for e-commerce has evolved significantly. The government’s introduction of Tables 14 and 15, along with Section 9(5) and Section 52, aims to:

ü  Clearly separate responsibilities between suppliers and ECOs

ü  Track revenue and tax liability efficiently

ü  Reduce tax evasion via platforms

But this also means businesses need to be more vigilant than ever. One small error in return filing — such as reporting in the wrong table or missing TCS credit — can lead to:

ü  Show-cause notices

ü  Blocking of ITC

ü  Penalties and interest

To stay compliant, businesses should invest in training, system upgrades, and regular reconciliation.

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