In re Dharmaraju Ragul (GST AAR Tamil Nadu)
Tamil Nadu Authority for Advance Ruling (AAR), in the case of In re Dharmaraju Ragul, has provided clarity on the Goods and Services Tax (GST) implications for individuals planning to rent or lease goods carriages to Goods Transport Agencies (GTAs). The ruling, issued on an application by an unregistered entity, Dharmaraju Ragul, confirms that such a supply, while taxable, is eligible for a ‘Nil’ rate of tax under existing notifications, provided certain conditions are met by the service receiver.
Dharmaraju Ragul, an unregistered individual, sought an advance ruling on the GST applicability of renting or leasing a goods carriage to a GTA. The applicant intended to purchase a goods carriage, specifically a ‘Reefer Vehicle,’ and lease it for five years to M/s. Celcius Logistics Solutions Private Limited, a company engaged in cold chain logistics and acting as a GTA. The primary queries raised were:
1.Whether the supply of a goods carriage on lease to a GTA is a taxable supply.
2. If it is an exempted/nil-rated supply, what conditions need to be satisfied to avail the exemption.
3. Whether the service provider (the applicant) needs to be a GTA to avail the exemption.
Applicant’s Contention and Legal Interpretation
