In re Shreyans Logistics Private Limited (GST AAR Odisha)
Odisha Authority for Advance Ruling (AAR) has determined the classification and applicable Goods and Services Tax (GST) rate for “Vehicle Leasing and Logistics Management Services” provided by M/s. Shreyans Logistics Private Limited. The AAR ruled that these services are taxable at 18% and are not exempt from GST.
M/s. Shreyans Logistics Private Limited, an entity aiming to provide integrated vehicle leasing and logistics management to Goods Transport Agencies (GTAs), sought an advance ruling on the appropriate HSN/SAC code and the GST rate or exemption status for their services. The company’s proposed business model involves leasing goods transport vehicles/trucks to GTAs, along with providing management and supervision of transportation operations. This includes aspects such as vehicle upkeep, maintenance, supervision of loading/unloading, weighment, transportation on pre-specified routes, and supervision of refueling. Crucially, the applicant does not provide operators/drivers with the vehicles, and the cost of fuel is borne by the recipient GTA.
The applicant contended that their services, being a combination of leasing and integrated logistics management, should be classified under HSN 997319, a residual entry for leasing or rental services of goods without an operator. They also argued that these services might be exempt from GST under Sl. No. 22 of Notification No. 12/2017 – CT(R) dated June 28, 2017, as “giving on hire” of goods transport vehicles, given that the GTA would have effective right and control over the vehicles.
