In re Tvl. Flipkart India Private Limited (GST AAR Tamilnadu)
The applicant, registered under the GST law in Tamil Nadu, filed an application for advance ruling under Section 97 of the CGST Act, 2017 and the corresponding provisions of the TNGST Act, 2017, after paying the prescribed application fees. The application sought clarification on two issues arising from a proposed new business model: first, whether transportation services of goods exclusively by road, provided to customers purchasing goods through e-commerce operator portals, would qualify as “Goods Transport Agency” (GTA) services; and second, whether such services provided to unregistered customers would be exempt from GST under Sl. No. 21A of Notification No. 12/2017–Central Tax (Rate), dated 28.06.2017, as amended.
Under the proposed model, when goods are purchased through an e-commerce portal, sellers would deliver the goods to a designated “Source Mother Hub”. From there, the applicant would collect the goods and transport them by road to the end customer’s delivery address. The applicant would issue a single consignment note covering the entire journey, irrespective of intermediate transit points or the use of multiple vehicles. The transportation charges would ultimately be borne by the end customer, though collected through the e-commerce operator for administrative convenience and remitted to the applicant. The applicant would raise tax invoices for transportation charges, and the consignment note would create a lien over the goods and make the applicant responsible for the goods until delivery.
