PMC services under SAC 998339
The SAC annexure lists project management services for construction projects as 998339, within group 99833 engineering services. They are taxed at 18%. Quantity surveying, cost consultancy and contract administration performed as part of the PMC scope are usually billed under the same code; standalone cost consultancy may fit elsewhere, but consistency matters more than precision across similar bills.
Place of supply for project-linked services
Section 12(3) of the IGST Act covers services directly in relation to immovable property, including services by engineers and coordination of construction work. A PMC managing a hospital project in another state therefore supplies service in that state. Firms with long-running projects in several states often register in each, issuing invoices from the local GSTIN with that state's CGST and SGST.
Reimbursements and pure agents
Travel and accommodation booked by the PMC in its own name and recovered from the client are part of the value of the service and attract 18%. Only costs meeting all Rule 33 pure-agent conditions, such as statutory fees paid in the client's name, can be excluded. Many PMCs mistakenly show all reimbursements as non-taxable.
Government and PSU clients
PMC services for Government projects attract 18% and are subject to 2% GST TDS for contracts above ₹2.5 lakh. Government clients often require detailed staff deployment records; your invoice should match them to avoid deductions.
E-invoicing for large consultancies
PMC firms often exceed the ₹5 crore aggregate turnover limit for e-invoicing. Every B2B invoice must then be reported on the Invoice Registration Portal and carry an IRN and QR code. Invoices without IRN are not valid for the client's credit and may be returned.
Percentage-of-cost fees and revisions
Some PMC agreements pay a percentage of the final construction cost. Monthly invoices are then raised on the estimated cost, with a final adjustment once the contractor's final bill is certified. If the cost increases, the additional fee is billed by a debit note or supplementary invoice referencing the earlier invoices; if it decreases, a credit note reduces your output tax, subject to section 34 time limits. Keep a fee reconciliation schedule so the last invoice shows how the cumulative fee was computed against the certified cost.
Advances and mobilisation of the PMC team
Clients sometimes pay a mobilisation advance when the PMC deploys its site team. GST on an advance for services is payable when received, using a receipt voucher, and the advance is adjusted in later monthly invoices. If the project is suspended and the advance is partly refunded, issue a refund voucher to adjust the tax.