In re Snag & Bag Retail Private Limited (GST AAR Tamil Nadu)
The Authority for Advance Ruling, Tamil Nadu, examined an application filed under Section 97 of the CGST Act, 2017 and the corresponding provisions of the TNGST Act, 2017 by a registered entity engaged in retail, wholesale, and service activities involving overseas vendors and customers located both in India and abroad. The applicant sought advance rulings on multiple questions relating to classification of goods or services with applicable HSN/SAC and GST rates, categorisation of its business model, determination of time and value of supply, eligibility for refund of input tax credit, correct invoicing treatment under export or zero-rated categories, and the requirement of GST registration.
The applicant explained its business model during the personal hearing and through written submissions. It stated that it provides consulting and management services to an Indian client and also acts as an intermediary or agent for sourcing goods from overseas vendors. In this arrangement, goods are purchased from vendors located outside India, invoiced to an Indian customer, and delivered directly outside India, without entering Indian territory. Payments are received in India from the Indian customer and remitted to foreign vendors. The applicant admitted that the goods never enter India and that there is no foreign currency realisation into India in respect of the goods transaction.
