Central Tax (Rate)General for ecommerce sellers
Central tax payment rule for Toll-Operate-Transfer road and highway concessionaires
Official text · Summary prepared automatically
- Document
- Notification No. 10/2026-Central Tax (Rate)
- Issued
- 28 Oct 2026
- Effective
- 1 Nov 2026
- Issued by
- Government of India, Ministry of Finance (Department of Revenue), Central Government
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What it means for ecommerce sellers
Notification No. 10/2026-Central Tax (Rate), issued under section 148 of the Central Goods and Services Tax Act, 2017, provides that a concessionaire under a Toll-Operate-Transfer concession agreement pays central tax on operation and maintenance services supplied to the concessioning authority on the amount charged or debited from the Escrow Account towards those expenses, in the tax period in which it is so charged or debited. It applies only to concessionaires holding exclusive toll rights over a road or highway who pay the concession fee upfront, with effect from 1 November 2026. It does not concern ecommerce or marketplace sellers.
Who it affects
- Concessionaires under a Toll-Operate-Transfer concession agreement who supply operation and maintenance services to the concessioning authority during the concession period
- Concessioning authorities: the Central Government, State Government, Union territory, local authority, Governmental Authority or Government Entity which enters into the Concession Agreement
What to do
- A concessionaire covered by the notification would pay central tax on operation and maintenance services on the amount charged or debited from the Escrow Account towards operation and maintenance expenses, in the tax period in which that expenditure is so charged or debited, from 1 November 2026.
Provisions referred to: Section 148 of the Central Goods and Services Tax Act, 2017
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Official text
As issued by Government of India, Ministry of Finance (Department of Revenue), Central Government. Where the text starts with “Extract”, only the parts that concern ecommerce sellers are reproduced; the official PDF (opens in a new tab) is the authoritative version.
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Questions sellers ask
Does Notification No. 10/2026-Central Tax (Rate) affect ecommerce or marketplace sellers?
No. Notification No. 10/2026-Central Tax (Rate) notifies only one class of registered person: a concessionaire under a concession agreement who supplies operation and maintenance services to the concessioning authority during the concession period, under the Toll-Operate-Transfer model for a road or highway. It does not mention ecommerce operators, marketplace sellers or D2C brands, so their tax payment position is not changed by it.
When does a Toll-Operate-Transfer concessionaire pay central tax on operation and maintenance services?
Under Notification No. 10/2026-Central Tax (Rate), a concessionaire pays central tax on operation and maintenance services supplied to the concessioning authority on the amount charged or debited from the Escrow Account, maintained in accordance with the concession agreement, towards operation and maintenance expenses. The tax is payable in the tax period in which such expenditure is so charged or debited. The notification comes into force from 1 November 2026.
What is a concession agreement under the Toll-Operate-Transfer model for GST purposes?
Notification No. 10/2026-Central Tax (Rate) defines a Concession Agreement as one between a concessionaire and the concessioning authority under the Toll-Operate-Transfer model, granting the concessionaire exclusive rights to demand, collect and appropriate toll on a road or highway, requiring it to operate and maintain that road or highway during the concession period, and where the concessionaire is required to pay the concession fee upfront.
Who counts as a concessioning authority under the Toll-Operate-Transfer GST notification?
Notification No. 10/2026-Central Tax (Rate) defines the concessioning authority as the Central Government, State Government, Union territory, local authority, Governmental Authority or Government Entity which enters into the Concession Agreement. The payment rule, notified under section 148 of the Central Goods and Services Tax Act, 2017, covers operation and maintenance services that a concessionaire supplies to such an authority during the concession period.
Want help working out what this means for your business?
We handle GST and TDS compliance, returns and notice replies for D2C and marketplace sellers, and can walk you through how a change applies to your books.
General information only, not professional advice. The summary is ecomca’s reading of the document; the official PDF is the authoritative version, and later amendments may change it. Check the official source before you act.