Mere renting of space cannot be said to be service for storage or warehousing of goods

In re M/s Karnataka Food & Civil Supplies Corporation (GST AAAR Karnataka) CWC is only providing the 488 sq metres of space in the central warehouse for rent. The space has been taken on rent by the Appellant for storing the food grains. The activity which is under consideration here is the activity performed by CWC and not the activity undertaken by the Appellant. The supply made by CWC is merely a renting of space. We observe that there is difference between ‘storage or warehousing’ service and ‘renting of storage premises’ service. The ‘storage and warehous...