In re A V Cargo Migrators LLP (GST AAR Tamilnadu)
The Applicant operates as an E-commerce platform that arranges transportation of goods between vehicle owners/drivers (referred to as transporters) and customers who need their goods transported.
The Authority for Advance Ruling, Tamil Nadu examined an application filed by an entity operating an electronic platform that connects transporters (vehicle owners/drivers) with customers seeking transportation of goods. The applicant sought clarity on whether it qualifies as a “Goods Transport Agency” (GTA) or an “E-commerce operator” and the taxability of its services under GST.
The applicant stated that it operates a digital platform where customers can book transporters, and revenue is generated through commission deducted either from the transporter’s pre-deposit or from payments received from customers. The applicant contended that it does not directly undertake transportation or issue consignment notes, and therefore should not be classified as a GTA. It also claimed that it acts as a “pure agent” in certain transactions and that transportation services by road are generally exempt unless provided by a GTA.
The Authority examined the statutory definition of a GTA, which requires provision of transport of goods by road along with issuance of a consignment note. It found that the applicant neither undertakes transportation nor issues consignment notes or performs ancillary activities such as loading, unloading, or warehousing. Accordingly, the applicant does not qualify as a GTA.
