Rule 11- Passenger Transportation Services
1. What is the place of provision of passenger transportation services?
The place of provision of a passenger transportation service is the place where the passenger embarks on the conveyance for a continuous journey.
2. What does a “continuous journey” mean?
A “continuous journey” means a journey for which:-
(i) a single ticket has been issued for the entire journey; or
(ii) more than one ticket or invoice has been issued for the journey, by one service provider, or by an agent on behalf of more than one service providers, at the same time, and there is no scheduled stopover in the journey
3 What is a “stopover”?
“Stopover” means a place where a passenger disembarks from the conveyance
4. The Table below contains illustrations which explain the principle enunciated in this Rule.
Illustrations
| S. No. | Journey | Place of Provision | Taxability |
| Single Ticket | |||
| 1 | Mumbai-Delhi | Mumbai | Yes, Mumbai, being the place of only embarkation |
| 2 | Mumbai-Delhi-Mumbai | Mumbai | Yes, Mumbai, being the place of embarkation where the continuous journey begins |
| 3 | Mumbai-Delhi-London- Delhi-London | Mumbai | -do- |
| 4 | Delhi-London-New York- London-New York | Delhi | Yes, New Delhi, being the place of provision for continuous journey with single ticket |
| 5 | Delhi-London-New York | Delhi | -do- |
| 6 | New York-London-Delhi | New York | No, New York is place of provision for continuous journey with single ticket |
| 7 | New York-London-Delhi- Mumbai-Delhi-LondonNew York | New York | -do- |
| More than one ticket for a journey (issued by a single service provider, or by a single agent, for more than one service providers) | |||
| 1 | (a) Delhi-Bangkok-Delhi (b) Bangkok-Bali- Bangkok |
Delhi is place of provision for journey (a); Bangkok is place of provision for journey (b) |
Journey (a) is taxable since place of provision is in taxable territory;
Journey (b) is not taxable since place of provision is outside taxable territory |
| 2
|
(a) Delhi-New York-Delhi (b) New York-Boston-New York | Delhi is place of provision for journey
(a); New York is place of provision for journey (b) |
Journey (a) is taxable since place of provision is in taxable territory;
Journey (b) is not taxable since place of provision is not in taxable territory. |
| 3 | (a) London-Delhi- London(b)Delhi-Chandigarh(c) Chandigarh-Amritsar (d) Amritsar-Delhi |
London is place of provision for journey Delhi is place of provision for journey Chandigarh is place of provision for journey (c); Amritsar is place of provision for journey (d) | Journey (a) is not taxable since place of provision is outside taxable territory;
Journeys (b), (c) and (d) are taxable since place of provision is in taxable territory. |
| 4 | a) Jammu-Delhi-Jammu b) Delhi-Bangkok-Delhi |
Jammu is place of provision for journey
(a); Delhi is place of provision for journey |
Journey (a)is not taxable since place of provision is outside taxable territory
Journey (b) is taxable, since place of provision is in taxable territory |
| 5 | a)Jammu-Delhi
b) Delhi-Bangkok-Delhi c) Delhi-Lucknow d) Lucknow-Jammu |
Jammu is place of provision for journey Delhi is place of provisio for journey Delhi is place of provision for journey |
Journey (a) is not taxable since place of provision is not in taxable territory;
Journeys (b), (c) and (d) are taxable since place of provision is in taxable territory. |
Hi, was wondering in what kind of a situation, separate tickets would be issued and they would form part of a ‘continuous journey’:
“…by an agent on behalf of more than one service providers, at the same time, and there is no scheduled stopover in the journey”.