In re Citius Holidays Private Limited (GST AAR West Bengal)
In Authority for Advance Ruling, West Bengal, an advance ruling was sought to determine the eligibility of Input Tax Credit (ITC) on food and beverage services procured by an applicant engaged in event management and tourism services. The applicant provides comprehensive event packages to corporate clients for conferences, offsite meetings, and training programs, which include booking of hotels, conference halls, accommodation, and arrangement of food and beverages. These services are procured from hotels, which generally issue a single invoice—sometimes itemized and sometimes consolidated—for bundled services such as room accommodation, conference facilities, and food. The applicant, in turn, charges clients a consolidated event management fee.
The applicant approached the Authority under Section 97 of the CGST Act seeking clarity on six issues, primarily concerning the applicability of Section 17(5)(b)(i), which blocks ITC on food and beverages, and the scope of the proviso that allows ITC when such inward supplies are used as an element of a taxable composite or mixed supply. The applicant contended that event management services constitute a composite supply, with event management as the principal supply and food and beverages as ancillary elements. On this basis, it was argued that ITC should be admissible under the proviso to Section 17(5)(b)(i). The applicant also submitted that GST law does not mandate separate invoices for different components of a composite supply and that a consolidated invoice from the hotel should suffice for availing ITC, subject to fulfillment of conditions under Section 16.
