Whether your housing society owes GST on EV charging recovered from members depends on how it bills; neither circular below names EV charging. Circular No. 206/18/2023-GST says an RWA charging members for electricity exactly what the DISCOM charged it is "deemed to be acting as pure agent", so that amount is outside the value of its supply. Circular No. 109/28/2019-GST states that an RWA's charges up to "Rs. 7500 per month per member" are exempt, and an RWA within "Rs.20 Lakh" annual turnover need not register; we have not confirmed those 2019 figures are current. A service charge, flat fee or operator income can change that. This is not legal or tax advice; confirm it with your society's chartered accountant.
The short answer: how you bill decides it, and two circulars frame most cases
This page covers only the tax consequence of a model already chosen; how housing societies bill EV charging explains the models. A separate DISCOM meter is left out: the society collects nothing for those units.
| How the society recovers EV charging | What the documents say | What stays unsettled | Question for your CA |
|---|---|---|---|
| Society sub-meter, smart charger or common-meter reimbursement, at exactly the DISCOM's amount | Circ. 206 para 3.3: charging "the same amount" makes the society a deemed pure agent | Whether an apportioned rate or an estimate is "the same amount"; whether EV charging is "electricity" | Is our rate the same amount, and does para 3.3 reach EV charging? |
| Sub-meter or smart charger plus a per-unit service charge | Para 3.3 covers only "the same amount", not the service element | Whether that element counts toward the Rs. 7500 test and turnover | Does the service element carry the electricity with it? |
| Flat monthly fee | Circ. 109: exempt up to "Rs. 7500/- per month per member"; above it "the entire amount is taxable" | Whether the EV part is "electricity charges" the flyer excludes | Does our EV fee count toward the limit? |
| Operator bills residents directly | Not addressed; the operator, not the society, bills the units | What the society receives | Is what we receive taxable? |
| Rent or revenue share from an operator | Not addressed; it is the society's own receipt | Whether it counts toward aggregate turnover | Does it bring us near "Rs.20 Lakh"? |
Recovering exactly the DISCOM's amount: the pure-agent rule
Circular No. 206/18/2023-GST, Ministry of Finance, Department of Revenue (Tax Research Unit), 31 October 2023 (gstcouncil.gov.in; last verified 15 October 2026), mentions RWAs only in para 3.3: "where they charge for electricity on actual basis that is, they charge the same amount for electricity from their lessees or occupants as charged by the State Electricity Boards or DISCOMs from them, they will be deemed to be acting as pure agent for this supply."
Para 3.3 has two limbs: electricity supplied "as a pure agent" "will not form part of value of their supply", and charging the DISCOM's own amount is deemed pure agency. Para 3.2 points the other way where electricity is bundled with maintenance: "Even if electricity is billed separately, the supplies will constitute a composite supply".
Two things stay open. Is your rate really the same amount? A landed cost per unit (bill total ÷ units) folds in fixed charges, and the circular does not say whether that qualifies (see reading your electricity bill). And is EV charging "electricity" for para 3.3 at all?
The Authority for Advance Rulings, Karnataka, in KAR ADRG 24/2023 of 13 July 2023 (gstcouncil.gov.in; last verified 15 October 2026), ruled on a Karnataka DISCOM's own charging stations that "The 'supply of electrical energy' and 'service charges' together are to be treated as 'supply of service'". Under section 103(1) of the Central Goods and Services Tax Act, 2017, a ruling "shall be binding only" on the applicant and its jurisdictional officer (CBIC's consolidation as on 30 September 2020, cbic-gst.gov.in; last verified 15 October 2026). It binds no society.
Readings must come from a meter specified and certified by a licensed electrician (see sub-meter versus smart-charger billing). Put both questions to your CA.
Folding EV charging into maintenance: the Rs. 7500 and Rs. 20 lakh tests
Circular No. 109/28/2019-GST, from the same Tax Research Unit, F. No. 332/04/2017-TRU, 22 July 2019 (gstcouncil.gov.in; last verified 15 October 2026), says:
- Issue 1. An RWA that is an "unincorporated body or a non-profit entity registered under any law" is exempt on charges to its members "up to an amount of Rs. 7500 per month per member for providing services and goods for the common use of its members".
- Issue 2. "If aggregate turnover of an RWA does not exceed Rs.20 Lakh in a financial year, it shall not be required to take registration and pay GST".
- Issue 4. The limit applies "separately for each residential apartment".
- Issue 5. Above the limit, "the entire amount is taxable", not just the excess.
It traces the limit to clause (c) of Sl. No. 77 of Notification No. 12/2017-Central Tax (Rate), as amended by Notification No. 2/2018. We could not fetch its current text from a government host, so have not confirmed either figure is unchanged since 2019. A circular is the department's reading of that entry; ask your CA for the current entry and whether any court ruling binding in your state reads it differently.
Circular 109 never mentions electricity. The exclusion rests only on an undated CBIC flyer, "GST on Housing Societies", from the Directorate General of Taxpayer Services (gstcouncil.gov.in; last verified 15 October 2026). Reasoning "assuming that a housing society is a non-profit registered entity", it says: "charges, collected by the society on account of property tax, electricity charges and other statutory levies would be excluded while calculating the limit of Rs. 7,500/-." Its FAQ says electricity charges "collected under other statutes" are not taxed, but charges collected "for generation of electricity by Society's generator or ... any other service" are "liable to GST".
The core tension: the flyer excludes "electricity charges" from the limit, while the Karnataka ruling, binding only on its applicant, treated electricity plus service charge at a charger as one supply of service. Which describes your EV line, and is a private bay "for the common use of its members"? If the sums are material, consider an advance ruling in your state.
Adding a service charge, or letting an operator bill residents
A service charge is not "the same amount", so para 3.3's deeming does not reach it; whether the DISCOM line beside it still qualifies is open. So is whether the charge counts toward the Rs. 7500 test and turnover, or carries the electricity into one supply as the Karnataka ruling found for its applicant; ask your CA. Pricing it is a committee decision (see budgeting a society charging station).
The Ministry of Power's Guidelines for Installation and Operation of Electric Vehicle Charging Infrastructure-2024, 17 September 2024 (beeindia.gov.in; last verified 15 October 2026), list "GST as applicable" in clause 8(d) among a Charge Point Operator's fee components and state the clause 10(1) ceiling "(excluding GST & land cost)"; neither clause says whether a society is liable.
Where an operator bills residents directly, ask whether what the society receives, such as rent or a revenue share, counts toward turnover; contract terms are in the operator deal check.
The treasurer's worksheet: run both tests on your own books
Every figure below is an assumption; substitute your own books.
- List each flat's monthly bill by line, per flat, not per owner (Issue 4).
- Label the EV line: DISCOM amount, plus a service charge, or flat fee.
- Total each bill with and without the EV line, against "Rs. 7500/-".
- Take the year's aggregate turnover, as your CA computes it, with and without EV items, against "Rs.20 Lakh".
- Take every case where the answer flips to your CA.
Suppose flat 304's maintenance is ₹6,500 and its EV line ₹1,400 this month: ₹6,500 + ₹1,400 = ₹7,900, above Circular 109's "Rs. 7500/-", while ₹6,500 alone is below. If the EV line counts, Issue 5 puts all ₹7,900 in question, not just the excess. Suppose your CA puts turnover at ₹18,40,000 before EV items, which add ₹2,60,000: ₹18,40,000 + ₹2,60,000 = ₹21,00,000, past "Rs.20 Lakh". We state no GST rate; which lines count, and at what rate, is for your CA.
Questions to put to your CA in writing
Ask for a written reply that names its sources, and minute it.
- Is our rate "the same amount" under Circular 206 para 3.3, given how we apportion fixed charges?
- Is our EV line "electricity charges" under the flyer, or "any other service"?
- Do a service charge, flat fee, rent or revenue share count toward the Rs. 7500 test or turnover?
- Are the Rs. 7500 and Rs.20 Lakh figures current, and does a court ruling binding here read them differently?
- Should we seek an advance ruling in our state?
Common questions
If our society recovers exactly what the DISCOM charges for EV units, is GST payable on that amount?
Circular 206/18/2023-GST, para 3.3, deems an RWA that charges "the same amount" as the DISCOM a pure agent, so that amount is not part of the value of its supply. Your CA must still say whether your apportioned rate is the same amount, and whether EV charging is electricity at all.
Does a member's EV charging recovery count towards the Rs. 7500 per month limit?
No cited document says. Circular 109 never mentions electricity; the undated CBIC flyer excludes "electricity charges" from the limit but treats charges collected to provide "any other service" as liable to GST. Which applies to EV charging is your CA's question.
Our society's annual turnover is under Rs. 20 lakh. Do we need GST registration because of EV charging?
Circular 109, Issue 2, says an RWA whose aggregate turnover "does not exceed Rs.20 Lakh in a financial year" need not register. We have not confirmed the figure is current, and whether EV items count toward turnover is your CA's call.
If a member's monthly bill crosses Rs. 7500, is GST due on the excess or on the whole amount?
Circular 109, Issue 5, says above the limit "the entire amount is taxable", not the excess; Issue 2 adds that GST is due only if the turnover test is also crossed. That is the department's clarification: ask your CA whether it is current, whether a court ruling binding in your state differs, and whether the EV line counts at all.
Does it change anything if an operator bills residents directly instead of the society?
No cited document addresses it. The operator, not the society, then bills the units; what the society receives, such as rent or a revenue share, is its own receipt; whether it counts toward turnover is for your CA.