Text
The text below is the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.[1] The Act as published in the Gazette of India is the legal source.
Section 86, verbatim (show)
*
Section 86. Liability of agent and principal.-
Where an agent supplies or receives any taxable goods on behalf of his principal, such agent and his principal shall, jointly and severally, be liable to pay the tax payable on such goods under this Act.
*Enforced w.e.f. 1st July, 2017.
Questions to answer on the file
Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.
Scope the section as a whole
Questions to answer on the file2 questions
The agent and the principal section 86 read with clauses (5) and (88) of section 2
Questions to answer on the file3 questions
The supply or receipt of taxable goods on behalf of the principal section 86 opening words
Questions to answer on the file6 questions
The joint and several liability section 86 closing words
Questions to answer on the file3 questions
Amendment history
The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]
| Note | Change | Instrument | Effective from |
|---|---|---|---|
| brought section 86 into force | none — the source's own enforcement note, not an amendment footnote | 1 July 2017 |
Relationship with other provisions
| Provision | Connection | Words that tie them |
|---|---|---|
| Section 2 | this provision defined by Section 2 clause (5) | 86 "Where an agent"; 2(5) "agent means a person, including a factor, broker, commission agent, arhatia, del credere agent, an auctioneer or any other mercantile agent, by whatever name called" |
| Section 2 | this provision defined by Section 2 clause (88) | 86 "on behalf of his principal"; 2(88) "principal means a person on whose behalf an agent carries on the business of supply or receipt of goods or services or both" |
| Section 2 | this provision defined by Section 2 clause (52) | 86 "any taxable goods"; 2(52) "goods means every kind of movable property other than money and securities" |
| Section 9 | this provision requires Section 9 | 86 "the tax payable on such goods under this Act", the charge being laid by section 9 |
| P3 of the SCHEDULE_I | P3 of the SCHEDULE_I same as this provision | Schedule I (3) "Supply of goods- (a) by a principal to his agent where the agent undertakes to supply such goods on behalf of the principal; or (b) by an agent to his principal where the agent undertakes to receive such goods on behalf of the principal" |
| Section 24 | Section 24 clause (vii) same as this provision | 24(vii) "persons who make taxable supply of goods or services or both on behalf of other taxable persons whether as an agent or otherwise" |
Circulars and notifications
No circular or notification in the CBIC repository is recorded as citing this section.
Unsettled questions
The words of section 86 do not answer this question. Where one decides a matter on the file, the answer depends on the position taken on it.
- Section 86 fastens the liability on the supply or receipt of "any taxable goods". The Act defines "goods" (clause (52) of section 2) and "taxable supply" (clause (108) of section 2), but nowhere defines "taxable goods". Does the expression mean goods forming part of a supply leviable to tax under this Act, or goods that are not wholly exempt, or goods of a description on which a rate has been notified?
See also
- Section 2 of the CGST Act, 2017: definitions
- Section 9 of the CGST Act, 2017: levy and collection
- Section 24 of the CGST Act, 2017: compulsory registration in certain cases
References
- Central Board of Indirect Taxes and Customs. "Section 86. Liability of agent and principal". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.
External links
- CGST Act, 2017, Section 86 on the CBIC tax information portal