Liability to RCM in case where Power of attorney is given.

This query is : Resolved

Chartered Accountant (Querist)
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04 April 2025 One of my client named X is a legal owner of a marble mines he has sublet his mines to Y, since subletting is not legally allowed in mining laws he has given power of attorney to Y for operating the mines, now the mining owner has to pay royalty to government and GST on RCM basis on royalty at 18%, both X & Y are registered under GST, all the legal expenses and tax will be borne by Y as per their agreement now my question is:
Who is liable to deposit GST on RCM basis X or Y?
I think the correct contention is that X should deposit the GST on RCM basis but as Y is paying the tax out of his pocket he would always want the input so X should show sales in the name of Y so that he can get the input and Y further sell it to 3rd party or Can Y directly pay RCM on royalty?