Case Law Details
In re Payline Technology Private Limited (GST AAAR Uttar Pradesh)
The Appellate Authority for Advance Rulings (AAAR), Uttar Pradesh, recently overturned a previous ruling by the Authority for Advance Ruling (AAR) regarding the applicability of Goods and Services Tax (GST) on the supply and trading of gift cards, vouchers, and prepaid vouchers by Payline Technology Pvt. Ltd. The ruling, given by the AAAR, redefines the treatment of such instruments under GST laws and specifies when and how tax should be applied.
Background
On February 20, 2024, an advance ruling (UP ADRG-43/2024) was issued by the AAR, holding that gift cards and prepaid vouchers supplied by Payline Technology were taxable as goods. However, this interpretation was challenged by Payline Technology in the AAAR, resulting in the new ruling issued in October 2024.
The AAAR’s recent decision holds that such instruments are indeed taxable under GST as goods, with the time of supply determined as per Section 12(4) of the CGST Act, 2017. The authority clarified that GST is applicable to the commission or discount earned through the trading of these instruments, with tax liability arising when the vouchers are traded or sold. Additionally, it ruled that the value of the service would be the margin between the purchase and selling price of the vouchers.
Appeal Delay Condoned
Before examining the core issues in the appeal, the AAAR considered the delay in filing. According to the CGST Act, appeals should typically be filed within 30 days from the communication of the ruling, extendable to an additional 30 days in exceptional cases. In this instance, the appellant received the AAR ruling on May 25, 2024, and filed an appeal on July 11, 2024. The AAAR condoned the delay, allowing the appeal to proceed.
Shifting Business Description by the Appellant
The AAAR noted changes in Payline Technology’s description of its business across different submissions. Initially, the company stated it engaged in buying and selling various types of gift cards, vouchers, and prepaid vouchers, including closed or semi-closed vouchers redeemable at specific brands. However, in its subsequent submission dated August 28, 2024, Payline described its business as limited to closed-ended vouchers redeemable only from the issuing entity.
RBI Regulations and Voucher Classification
Gift cards and prepaid instruments are regulated by the Reserve Bank of India (RBI) under the Payment and Settlement Systems Act, 2007. RBI guidelines classify such prepaid payment instruments (PPIs) into three categories: closed, semi-closed, and open system instruments. Closed-system instruments can only be used for purchases within the issuing entity’s network, while semi-closed and open systems offer wider usage, with specific regulatory requirements.
In its ruling, the AAAR highlighted that Payline Technology does not issue these PPIs but trades them as a third-party buyer and seller. The AAAR rejected Payline’s argument that the instruments qualify as “money” and are therefore non-taxable under GST, noting that such instruments only become “money” when redeemed by the end-user. The AAAR clarified that since Payline Technology merely trades these vouchers, GST applies to the margin earned in such transactions.
Legal Interpretation of Vouchers under GST Law
Under the CGST Act, a voucher is defined in Section 2(118) as an instrument accepted as payment or part-payment for goods or services, and for which the supply or identity of suppliers is indicated. Section 12(4) specifies that the time of supply for vouchers occurs either at issuance (if supply is known) or at redemption.
Classification of Vouchers as Goods
The AAAR examined whether vouchers qualify as “goods” under the CGST Act, which defines goods as movable property excluding money and securities. It found that the vouchers purchased and sold by Payline Technology fall within this definition, as they carry intrinsic value and ownership, transferred from the issuer to Payline and then to the end-user.
The AAAR further discussed the concept of “actionable claims” under the Transfer of Property Act, 1882. An actionable claim, as defined in the act, includes a claim to unsecured debt or beneficial interest in movable property not in the possession of the claimant. Although GST typically excludes actionable claims from its scope, specific claims related to activities like betting, gambling, and lottery are taxable. The AAAR, however, concluded that gift vouchers sold by Payline do not qualify as actionable claims, since they represent a pre-loaded value but no direct claim to a debt or other beneficial interest.
Impact of the Ruling on Payline Technology
As per the AAAR, Payline Technology is liable to pay GST on the margin or commission it earns from trading gift cards and vouchers. The ruling clarifies that the company’s earnings from such trades are taxable as the difference between the purchase and selling prices. Furthermore, GST is payable when these vouchers are sold, consistent with the time of supply provision in Section 12(4).
Read AAR Order: Taxation of Vouchers as Supply of Goods and Time of Supply Under GST
FULL TEXT OF THE ORDER OF APPELLATE AUTHORITY FOR ADVANCE RULING,UTTAR PRADESH
At the outset, we would like to make it clear that the provisions of both the Central Goods and Service Tax Act and the Uttar Pradesh Goods and Service Tax Act are pari-materia and have the same provisions in like matter and differ from each other only on few specific provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the Central Goods and Service Tax Act, 2017 would also mean a reference to the same provisions under the Uttar Pradesh State Goods and Service Tax Act, 2017.
2.1. This appeal has been filed by M/s Payline Technology Private Limited, Basement, H-47, Cabin No.7, Block-H, Sector-63, Noida, Gautam Buddha Nagar, Uttar Pradesh — 201301 (hereinafter referred to as ‘Appellant’) against the advance ruling no. UP ADRG — 43/2024 dated 20.02.2024, made by the Uttar Pradesh State Authority for Advance Ruling.
2.2 The appellant is in the business of selling and purchasing Gift Cards, Vouchers, and pre-paid Vouchers (closed or semi-closed-ended vouchers against which goods or services can be purchased from specific brands on e-commerce platforms such as Amazon, Flipkart, etc.). These vouchers are purchased by the appellant from entities against advance payments and at a discounted price. Later, these vouchers are supplied to clients. Once these vouchers are purchased by the appellant from the original issuers, the appellant becomes the absolute owner of these vouchers, and both risk and reward lie with the appellant. The appellant is neither the issuing person nor the user of these Vouchers.
2.3 The Appellant had submitted application for Advance Ruling before the Authority of Advance Ruling for determination of following questions.
i. Whether the Vouchers themselves, or the act of supplying them is taxable, and at what stage, for each of the three categories of transaction undertaken by the appellant is taxable ?
ii. If the answer to the above question is in the affirmative, what would be the rate of tax and the value of supply at which this would be taxable ?
2.4 The application was disposed by Advance Ruling No. UP ADRG 43/2024 dated 20.02.2024 wherein the Authority held —
i. In respect of Question No. 1, that supply of Vouchers by the appellant are taxable @ 9% CGST & 9% UPGST as per residual entry no.453 of the Third Schedule of Notification No.01/2017-Central Tax (Rate) dt. 28.06.2017 (and similar notification under the UPGST Act).
ii. to Question No. 2, that value of supply of Vouchers in the present case shall be decided as per sub-section (1), (2) and (3) of Section 15 of the CGST Act, 2017.
3. Grounds of appeal: Being aggrieved by the aforesaid ruling, the Appellant preferred instant appeal on the ground that the members of authority of Advance Ruling has erred in appreciating the facts of the present case and legal provisions while passing the ruling.
4. Reason for delay in filing appeal before the Appellate Authority.
The appellant was of the opinion that the appeal is to be filed online only and was continuously checking the status of the order on the portal but till the date of filing appeal, no order was uploaded on the portal. So, the appellant physically procured the order from Lucknow and made appeal in person to the Appellate Authority.
5. Personal Hearing
The Authorised representative, Shri M a noj Kumar Goya!, C.A. of the party M/s Payline Technology Private Limited, Basement, H-47, Cabin No.7, Block-H, Sector 63, Noida, Gautam Buddha Nagar, Uttar Pradesh-201301, appeared for personal hearing on 27.08.2024 and argued their case and requested for two days’ time to submit additional defence. The party vide their letter dated 28.08.2024 received through email on 29.08.2024 submitted their additional defence/submission. Vide their letter dated 28.08.2024, they made following additional submissions:
5.1 That the appellant is in the business of selling and purchasing Gift cards, Vouchers and pre-paid Vouchers (Closed Vouchers against which goods or services can only be purchased from the issuing entity of the instruments/Vouchers).
5.2 That the instruments in question are very much in the nature of “money” and hence excluded from the definition of “Goods” as well as from “Services” making the supply of these instruments non-taxable.
5.3 That they rely on the judgment of Premier Sales Promotion Ltd.
5.4 That the goods/services in their case are not identifiable at the time of issuance, hence, the time of supply of such instruments shall fall at the time of their redemption which usually happens only after the instruments are sold to the end consumers by the appellant, hence, the tax liability on sale of instruments by them are not liable to tax.
Discussion and Findings
6.1 We have carefully gone through the records of the case and the submissions made by the Appellant in their application, defence made at the time of personal hearing and additional submissions submitted vide their letter dated 28.08.2024. Before getting into the discussion of the issue in the appeal, we find that there is a delay in filing the appeal. Hence the same needs to be examined first before moving forward to decide the issue raised in the Appeal
6.2.1 We find that in terms of Section 100 of the CGST Act, 2017, an appeal should be filed within 30 days from the date of communication of the advance ruling order that is sought to be challenged. As per the Appellant, the advance ruling dated 20.02.2024 was received by them on 25.05.2024 and the instant appeal has been received in the office on 11.07.2024. We find that the proviso to Section 100(2) of CGST Act, 2017, states that-
“Provided that the Appellate Authority may, if it is satisfied that the appellant was prevented by a sufficient cause from presenting the appeal within the said period of thirty days, allow it to be presented within a further period not exceeding thirty days. “
6.2.2 In the instant case, after going through the application of the appellant and in terms of the proviso to Section 100(2) of the CGST Act, 2017, we condone the delay.
7. On going through the Advance Ruling No. UP ADRG 43/2024 dated 20.02.2024, appeal filed by the appellant and the additional submissions dated 28.08.2024 filed by the appellant, we find that the appellant has changed their version about their business as under :
I. Earlier the appellant submitted before the Authority for Advance Ruling, GST, Uttar Pradesh as well as in their appeal filed in Form GST ARA-02 signed dated 05.06.2024 that “the appellant is in the business of selling and purchasing Gift Cards, Vouchers, and pre-paid Vouchers (closed or semi-closed-ended vouchers against which goods or services can be purchased from specific brands on e-commerce platforms such as Amazon, Flipkart, etc.)”.
I.. Now, the appellant vide letter dated 28.08.2024 submitted their additional submissions describing their business as “the appellant is in the business of selling and purchasing Gift Cards, Vouchers, and pre-paid Vouchers (closed vouchers against which goods or services can only be purchased from the issuing entity of the instruments/vouchers)”.
7.1 The issue of payment instruments in India is regulated by the Reserve Bank of India (RBI) in terms of the Payment and Settlement Systems Act, 2007 (P55) and the Guidelines issued there under. The RBI has issued a master direction [DPSS.CO.PD.No.1164/02.14.006/2017-18] on the issuance and operation of PPIs. These guidelines lay down the eligibility criteria and the basic conditions for payment system operators involved in the issuance of Pre-paid Payment Instruments (PPI) in the country. All persons proposing to operate payment systems and involved in the issuance of PPIs shall seek authorization from the Department of Payment and Settlement Systems, RBI, under the Payment and Settlement Systems Act, 2007. Few definitions relevant to instant case are given below :
i. Issuer : Persons operating the payment systems issuing pre-paid payment instruments to individuals/organizations. The money so collected is used by these persons to make payment to the merchants who are part of the acceptance arrangement directly, or through a settlement arrangement.
ii. Holder: Individuals/Organizations who acquire pre-paid payment instruments for purchase of goods and services, including financial services.
iii. Pre-paid Payment Instruments: Pre-paid payment instruments are payment instruments that facilitate purchase of goods and services, including funds transfer, against the value stored on such instruments. The value stored on such instruments represents the value paid for by the holders by cash, by debit to a bank account, or by credit card. The pre-paid instruments can be issued as smart cards, magnetic stripe cards, internet accounts, Internet wallets, mobile accounts, mobile wallets, paper vouchers and any such instrument which can be used to access the pre-paid amount (collectively called Prepaid Payment Instruments hereafter). The pre-paid payment instruments that can be issued in the country are classified under three categories viz. (i) Closed system payment instruments (ii) Semi-closed system payment instruments and (iii) Open system payment instruments.
iv. Closed System Payment Instruments: These are payment instruments issued by a person for facilitating the purchase of goods and services from him/it. These instruments do not permit cash withdrawal or redemption. As these instruments do not facilitate payments and settlement for third party services, issue and operation of such instruments are not classified as payment systems.
v. Semi-Closed System Payment Instruments: These are payment instruments which can be used for purchase of goods and services, including financial services at a group of clearly identified merchant locations/ establishments which have a specific contract with the issuer to accept the payment instruments. These instruments do not permit cash withdrawal or redemption by the holder.
vi. Open System Payment Instruments: These are payment instruments which can be used for purchase of goods and services, including financial services like funds transfer at any card accepting merchant locations (point of sale terminals) and also permit cash withdrawal at ATMs/BCs.
7.2 Thus, the pre-paid payment instruments (PPI, in short) that can be issued in India are classified under three categories: closed, semi-closed, and open system payment instruments. Closed system PPI’s can be issued by any entity for making supply of goods or services, exclusively from the said entity. Such closed ended PPIs cannot be used for cash payments/settlements or withdrawals. Semi-closed PPIs can be issued by Banks and nonbanking entities. Its functioning is similar to that of a closed PPI, as the same can be used for purchase of goods and services and the same cannot be withdrawn. However, unlike a closed PPI, semi-closed PPI can be used for settlements. Therefore, they require prior approval from RBI for issuance. An open system PPI can be issued only by a Bank. They can be used for both cash settlements/payments and withdrawals. Looking at these Guidelines, it is imperative to mention that these are mainly applicable to the issuers of the PPIs, and not to its traders.
7.3 In the present case, the Appellant is not the issuer of the voucher, but is the third party who buys and sells the vouchers. We find that in the additional submissions, the appellant has claimed that instruments in question are very much in the nature of “money” and hence excluded from the definition of “Goods” as well as from “Services” making the supply of these instruments non-taxable. The money is defined in terms of Sec.2(75) of CGST Act, 2017 as under :
” ‘money’ means the Indian legal tender or any foreign currency, cheque, promissory note, bill of exchange, letter of credit, draft, pay order, traveler’s cheque, money order, postal or electronic remittance or any other Instrument recognized by the Reserve Bank of India when used as a consideration to settle an obligation or exchange with Indian legal tender of another denomination but shall not include any currency that is held for its numismatic value.”
7.4 Thus, money is primarily used to settle an obligation or exchange with Indian legal tender of another denomination. We find that the appellant in their additional submissions has claimed that their Vouchers and pre-paid Vouchers are closed Vouchers, hence, they cannot be used by the Appellant to settle an obligation, therefore, they cannot be considered as “money”. Further, the definition of Closed System PP1s, provided by the RBI, in the master direction, defines that these instruments do not facilitate payments and settlement for third party services, and issue and operation of such instruments are not classified as payment systems. The Appellant is merely a trader of these Vouchers, which are not used to settle an obligation. These vouchers could be termed as ” money” only when it is redeemed by the beneficiary at the time of purchase of goods and /or services. The settlement of the obligation occurs at the time when the ultimate beneficiary uses the voucher to purchase goods and /or services. Therefore, the voucher In the hands of the Appellant cannot be termed as “money”.
8. Further, on examining the facts and records of the case we find that Voucher is defined as under :
8.1 What is a Voucher : Section 2(118) of GST Act defines: “voucher” means an instrument where there is an obligation to accept it as consideration or part consideration for a supply of goods or services or both and where the goods or services or both to be supplied or the identities of their potential suppliers are either indicated on the instrument itself or in related documentation, including the terms and conditions of use of such instrument;
8.2 Section 12(4) specifies that in case of supply of vouchers by a supplier, the time of supply shall be—
(a) the date of issue of voucher, if the supply is identifiable at that point; or
(b) the date of redemption of voucher, in all other cases.
8.3 Thus, as per GST laws, a voucher is an instrument that entitles the holder to receive goods or services or a discount on goods or services upon redemption. Vouchers are instruments representing value to facilitate a supply. Vouchers include gift cards, discount coupons, prepaid instruments, and similar items.
9. Is Voucher goods or service:
9.1 The definitions under CGST Act, 2017 are as under:
Sec.2(52) “goods” means every kind of movable property other than money and securities but includes actionable claim, growing crops, grass and things attached to or forming part of the land which are agreed to be severed before supply or under a contract of supply;
Sec.2(102) “services” means anything other than goods, money and securities but includes activities relating to the use of money or its conversion by cash or by any other mode, from one form, currency or denomination, to another form, currency or denomination for which a separate consideration Is charged;
[Explanation— For the removal of doubts, it is hereby clarified that the expression “services” includes facilitating or arranging transactions In securities;]
9.2 In the instant case the Appellant purchases the vouchers by paying a consideration to the issuer. The vouchers are also sold to the clients of the Appellant for a consideration. The vouchers have both a value and an ownership, which is transferred by the issuer of these vouchers to the appellant, and then to the ultimate beneficiary who redeems the voucher. Therefore, the vouchers qualify to be considered as movable property and the ” goods”
9.3 Next point to be considered is that whether the vouchers are in the nature of actionable claims. Actionable claim qualifies as ‘goods’. Actionable claim is defined to have the same meaning as assigned to it in section 3 of the Transfer of Property Act, 1882. Section 3 of defines it as under:
“actionable claim” means a claim to any debt, other than a debt secured by mortgage of immoveable property or by hypothecation or pledge of moveable property, or to any beneficial interest in moveable property not in the possession, either actual or constructive, of the claimant, which the Civil Courts recognise as affording grounds for relief, whether such debt or beneficial interest be existent, accruing, conditional or contingent:
9.4 Thus, actionable claim is a claim to an unsecured debt or a claim to any beneficial interest in movable property that is not in the possession of the claimant. Transactions/activities in actionable claims are kept outside the ambit of GST, except for the following claims: betting, casinos, gambling, horse racing, lottery and online money gaming.
9.5 Civil Courts adjudicate the beneficial interest in moveable property not in the possession, either actual or constructive, of the claimant, for relief, whether such debt or beneficial interest be existent, accruing, conditional or contingent.
9.6 The term “debt” is not defined in GST law. The term “debt” in P. Ramanatha Aiyer’s advanced law lexicon, debt means: A sum of money due from one person to another. A debt exists when a certain sum of money is owing from one person to another ‘Debt’ denotes not only the obligation of the debtor to pay, but also the right of the creditor to receive and enforce payment.
Consequently, vouchers or gift card could be said to be a claim to any debt, other than a debt secured by mortgage of immoveable property.
9.7 Actionable claims are considered “goods” under the CGST Act but have some special rules. They are only taxed when transferred, sold, or given away for a price. This means that GST is not charged on the debt itself but only on the supply of the right to recover the debt. This is because actionable claims are neither a supply of goods nor services as per Schedule III of the CGST Act. GST liability arises when the claim is assigned, sold, or disposed of for consideration. In case of Vouchers, it has already been observed that Voucher by itself is a movable property, and hence constitutes goods. Since the Voucher is in the possession of the claimant at the time of claim, hence it cannot be considered as actionable claim.
10.1 Trading of Vouchers amounts to supply of ‘goods’ or of ‘services’ — The Section 7(1)(a) of the CGST Act, 2017 read as under ;
Sec. 7. (I) For the purposes of this Act, the expression “supply, ‘ includes-
(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange, licence, rental, lease or disposal made or agreed to be made for a consideration by a person in the course or furtherance of business;
Here the appellant is involved in trading of vouchers for a consideration in the course of furtherance of business. Though profit motive Is not a requisite for the term supply, yet it is a fact that the Appellant is selling these vouchers at a profit. Thus, the impugned transaction amounts to supply of goods in terms of Section 7(1) (a) of the CGST Act 2017.
Further, Schedule II to Section 7 of the CGST Act 2017 stipulates the activities or transactions to be treated as supply of goods or supply of services. Para (a) of Schedule II to Section 7 specifies that any transfer of the title in goods is supply of goods. The transaction of sale of vouchers in the instant case Involves transfer of the title, and hence they are covered under ” goods”.
10.2 We observe that the Authority in its findings has observed the Vouchers in the instant case as ‘goods’ but have found that the time of supply shall be decided in terms of sub-section (2) of Section 12 of CGST Act, 2017 and Section 12(4) of the CGST Act, 2017 is not applicable in case of appellant. We find that Section 12(2) & 12(4) of the CGST Act, 2017 read as under :
Section 12(2) — The time of supply of goods shall be the earlier of the following dates, namely —
(a) The date of issue of invoice by the supplier or the last date on which he is
required, under Section 31, to issue the invoice with respect to the supply; or
(b) The date on which the supplier receives the payment with respect to the supply.’
Section 12(4)- In case of supply of vouchers by a supplier, the time of supply shall be —
(a) The dote of issue of voucher, if the supply is identifiable at that point; or
(b) The date of redemption of voucher, in all other cases.
10.3 Here we find that Section 12(4) of the CGST Act, 2017 is a specific provision for the deciding the time of supply of the vouchers and is applicable to the appellant. Thus, we hold that time of supply of vouchers will be determined in terms of Section 12(4) of the CGST Act, 2017.
11.1 We observe that that the appellant in their appeal have stated about their mode/method of transaction as under :
Appellant bought a gift cord worth Rs.1000/- from XYZ Company at a discount of 3%. This means appellant hos paid Rs.970/- for it. Later, appellant sold this gift card to ABC Company for Rs.975/- after giving them a discount of 2.5%. From this deal, appellant will earn a profit of Rs.5/-, and GST is paid when the vouchers are redeemed by the customers.
11.2 If the discount coupons are single-purpose vouchers (where the supply is identifiable), they are taxed at the point of sale. For multi-purpose vouchers (where specific goods/services are not identifiable at the time of issuance), GST is applicable upon redemption.
11.3 In relation to VAT, Hon’ble Supreme Court overruled the judgment of Bombay High Court that had classified coupons as goods in case of Sodexo Coupons [2015-TIOL-293-SC-Misc]. It clarified that vouchers are merely “payment instruments” and not ‘goods’ and they become taxable only when they are redeemed.
12.1 Under India’s Goods and Services Tax (GST) regime, all supplies are categorized as either “goods” or “services.” Every supply must be classified as either a supply of goods or a supply of services. There is no provision for the supply of items that are neither goods nor services. Even composite and mixed supplies are broken down into their components to determine the tax liability under GST.
However, some supplies might not attract GST if they fall under exemptions, but they still have to be classified as either goods or services. Items like money, securities, and certain actionable claims (like lottery tickets) are outside the GST purview but are still recognized as either goods or services.
Thus, there cannot be a supply that is neither goods nor services, but some supplies are non-taxable or exempt.
12.2 Under GST regime, the intention of lawmakers seems to be to levy tax on vouchers, as there are provisions in the law that define vouchers, the point of taxation thereof, and other aspects.
12.3 In the case of Yasha Overseas v Commissioner of Sales Tax (2015 (322) ELT 0007 S.C.), the apex court held that replenishment licences, considering their inherent value and free transferability, qualify as goods and are not merely an actionable claim.
12.4 If the coupons/vouchers represent a right to receive goods or services at a future date, and the trading activity Involves the transfer of these rights without any physical goods being exchanged, it has to be considered a service since as per the GST law, the activity of providing or transferring a right to use goods or services is service. Since coupons/vouchers are essentially instruments granting such a right, trading in them falls under the service category.
12.5 For an intermediary who arranges the distribution or sale of discount vouchers and earns a commission (in the form of discount in the instant case), the GST liability is determined based on the nature of the service provided—facilitating the distribution of vouchers and earning a commission fee/discount.
In the instant case the appellant is engaged in trading of Vouchers/coupons and getting commission in the form of discount, on such services which are taxable. Thus, trading in Vouchers/coupons, being a service, is the taxable event where the time of supply is when the Vouchers/coupons are traded or sold. The value of service shall be the margin between the buying and selling price of the coupons.
13. In view of the foregoing, we make the following order:
i. We set aside the impugned ruling given vide UP ADRG — 43/2024 dated 20.02.2024 passed by the Authority for Advance Ruling against the Appellant.
ii. The Supply of Gift cards/ Vouchers/ pre-paid Vouchers are taxable as supply of goods and the time of supply shall be decided as per Section 12(4) of the CGST Act, 2017.
iii. We hold that GST is applicable on the commission/discount earned in the trading of Vouchers/Coupons by the appellant and the time of supply will be the time when the Vouchers/Coupons are traded or sold. The value of service shall be the margin between the buying and selling price of the Vouchers/Coupons.
14.1 The Ruling given hereinabove applies to the unique facts and circumstances of the appellants’ matter in appeal and is based upon the submissions and evidences made available in this regard.
14.2 This ruling is valid only within the jurisdiction of Authority for Advance Ruling, Uttar Pradesh in terms of the provisions of The Central Goods and Services Tax act, 2017 and Uttar Pradesh Goods and Services Tax Act, 2017.
