Interactive Tool • 5% vs 18% GST, Sec 9(5) & Rule 42 Reversals

Restaurant & Hospitality Compliance Evaluator

Evaluate 5% no-ITC vs 18% hotel GST rate eligibility, model Section 9(5) Swiggy/Zomato delivery tax splits, calculate mandatory Section 17(2) Rule 42 common ITC reversals on alcohol sales, and project Section 35AD cold chain deductions. Computations execute 100% locally in your browser with zero server data storage under the DPDP Act 2023.

Operational & Revenue Parameters

Determines GST rate classification under Notification 11/2017-CT(R).

Declared room tariff above ₹7,500 triggers 18% GST with full ITC.

Dine-in, takeaway & delivery food

Turnover ordered via delivery apps

Non-GST supply under State VAT

GST paid on rent, electricity, POS, security

Capital expenditure on cold storage or warehouse (Sec 35AD)

Statutory Diagnostics

Live Audit Simulation
GST Rate & ITC Status 5% Without ITC

Mandatory 5% Dining Rate

Standalone dining cannot opt for 18% with ITC. Inward tax on rent, equipment, and fit-outs is non-creditable.

Applicable GST Rate: 5%
Input Tax Credit Eligibility: Blocked / No ITC
Section 9(5) Delivery Tax Swiggy / Zomato

E-Commerce Platform Split

Under Section 9(5), the ECO collects and deposits 5% GST in cash on app orders.

App Delivery Turnover: ₹1,05,00,000
5% Tax Paid by Swiggy/Zomato: ₹5,25,000
Direct Dine-In/Takeaway GST: ₹9,75,000
Report app sales in GSTR-3B Table 3.1.1(ii) to eliminate double tax demands.
Rule 42 ITC Reversal Reversal Required

Liquor Non-GST Apportionment

Section 17(2) mandates reversing inward GST on shared rent, power, and overheads for alcohol sales.

Alcohol Sales Ratio: 33.33%
Mandatory Common ITC Reversal: ₹6,00,00,000
Failure to reverse triggers Section 73/74 demands with 18% penal interest.
Section 35AD Capex Cold Chain Benefit
100% Upfront Capex Deduction: ₹0
Est. Corporate Tax Shield (~25.17%): ₹0

Applies to cold storage facilities and warehousing. Form 3CE electronic audit required.

Statutory Framework for Restaurants & Hospitality Businesses

1. The 5% No-ITC Mandate vs 18% Hotel Specified Premises

Under Notification No. 11/2017-Central Tax (Rate) as amended by Notification No. 20/2019-CT(Rate), standalone restaurants, cafes, and cloud kitchens are statutorily restricted to 5% GST without Input Tax Credit. Inward GST paid on commercial leases, kitchen fit-outs, equipment, and royalty cannot be claimed, representing a direct operational cost. However, restaurants located in hotel premises with any room having a declared tariff exceeding ₹7,500 per day ("specified premises") must levy 18% GST with full ITC eligibility.

2. Section 9(5) E-Commerce Operator (ECO) Reporting Discipline

Effective January 1, 2022, Notification No. 17/2021-CT(Rate) brought restaurant services under Section 9(5) of the CGST Act. Swiggy, Zomato, and other ECOs are deemed suppliers responsible for collecting and discharging 5% GST in cash on app orders. Restaurants must report such sales under Table 3.1.1(ii) of Form GSTR-3B and Table 8 of GSTR-1 as supplies made through ECO, preventing erroneous double taxation and automated notice issuance under Section 73/74.

3. Alcoholic Liquor Apportionment & CGST Rule 42 ITC Reversal

Alcoholic liquor for human consumption remains outside the constitutional remit of GST under Article 246A and is subject to State Excise and VAT. Under Section 17(2) read with Rule 42 of the CGST Rules, 2017, non-GST supplies are treated as exempt supplies for ITC apportionment. Multi-cuisine venues serving alcohol must compute proportionate reversals of common input taxes (commercial rent, electricity, maintenance, POS software) on a monthly basis, with final annual true-up before November 30.

4. Section 35AD Capex Incentives for Cold Chain Facilities

F&B businesses investing in post-harvest agricultural infrastructure, cold chains, or warehousing facilities for agricultural produce can claim a 100% upfront capital write-off under Section 35AD of the Income-tax Act, 1961 (and Section 35AD of the 2025 Act). An electronic audit in Form 3CE by an independent CA with UDIN is legally mandatory to validate asset capitalization and depreciation surrender.

Require Hospitality GST Structuring or Rule 42 Audit?

Consult our Hospitality Practice Desk for Section 9(5) Swiggy/Zomato reconciliations, liquor VAT reversals, and FSSAI audits.

Consult Hospitality Desk
ICAI Code of Ethics Pull-Model Statutory Notice This interactive diagnostic tool provides computational simulations for informational and planning purposes under direct and indirect tax statutes. Final tax positions require independent audit validation with formal UDIN.