Advance Ruling

Advance Ruling for Unregistered Dealers (FORM GST ARA-01)

Goods and Services Tax - FAQs on Advance Ruling for Unregistered Dealers (FORM GST ARA-01) Q.1 Who can I apply for Advance Ruling? Ans: Application for Advance Ruling can be filed by any person who is registered or is desirous of obtaining registration under this Act on the matters prescribed under the GST Act with payment of the prescribed fee. […]...

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GST Advance Ruling filing & Tracking / Taking Action in Subsequent Proceedings

Goods and Services Tax - A. FAQs on Filing Applications Related to Advance Ruling and Tracking or Taking Action in the Subsequent Proceedings Filing an application (FORM GST ARA-01) for seeking Advance Ruling by Registered Taxpayers Q.1 Who can apply for Advance Ruling? Ans: An application for Advance Ruling can be made by any person who is registered or is [&hel...

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Supreme Court urges for a vibrant & ‘redeveloped’ Advance Ruling System

Goods and Services Tax - Earlier this month, the Supreme Court adjudicated a 44-year old case pertaining to Finance Year 1975-76, in the case of National Co-Operative Development Corporation (a government corporation set up under the National Development Corporation Act). While concluding, the Court remarked on the present system of tax litigations that the Supre...

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All About Advance Ruling Authority Under GST

Goods and Services Tax - All about Advance Ruling under GST i.e. Section 95 to Section 106 of the CGST Act, 2017 Article explains Basic understanding of Advance Ruling, The broad objectives for setting up a mechanism of Advance Ruling, Applicability of Advance Ruling, Authority for Advance Ruling (AAR) & Appellate Authority for Advance Ruing (AAAR), Questions...

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ITC on Lift available or not under GST

Goods and Services Tax - Lift is not a machine , it is part of Building, is it true . is the ITC claimable on purchase of Lift . Let us discuss whether lift is machine or Building only we would reach to conclusion of ITC is eligibility. Section 17(5) blocks credit of works contract and goods or services received […]...

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GST Authorities of Advance/Appellate Rulings-Status Upto April 2019 

Goods and Services Tax - Authority for Advance Ruling (AAR) constituted under the provisions of a SGST/ UTGST Act, in terms of the provisions of Section 96 of the CGST Act, 2017 to render ruling on issues specified under Section 98 of the CGST/SGST Act which are binding on respective tax authority and tax payers. Being aggrieved by said Ruling, […]...

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Writ in Madras HC against constitution of GST Authority for Advance Rulings

Goods and Services Tax - Revenue Bar Association has filed and Writ Petition in Madras High Court under Article 226 of the Constitution of India seeking a writ of declaration to declare: a) Chapter XVII of the Central Goods and Services Tax Act, 2017, more particularly, sections 96 and 99 of the Central Goods and Services Tax Act, 2017 relating […]...

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Host all GST advance ruling judgement at one website

Goods and Services Tax - ICAI has requested Government to host all the advance ruling judgement at one website either at CBIC or GST Council. ICAI is Apex Body of Chartered Accountants in India. The Authority for Advance Ruling constituted under the GST Laws, have been delivering its judgement regularly on the various cases before it. Presently, there is no [&hel...

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Creation of two additional benches of the Authority for Advance Rulings (Income Tax)

Goods and Services Tax - The Union Cabinet chaired by the Prime Minister, Shri Narendra Modi, today gave its approval to the following:- i. Creation of two additional benches of the Authority for Advance Rulings (Income Tax), one in New Delhi and one new bench in Mumbai; ii. creation of two posts of Vice-Chairmen in the Apex scale and four […]...

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Concessional rate of tax for foreign oil exploration and production companies

Goods and Services Tax - Income of foreign companies providing technical services and data to oil exploration and production companies in India will be taxed at a concessional rate, the Authority for Advance Rulings (AAR) on income tax has said in a recent decision. The ruling will be a big help to oil prospecting companies in India as they step up exploration ac...

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5% GST on sale of Micafunign Sodium by DTA unit of BIOCON: AAAR

In re BIOCON Ltd. (GST AAR Karnataka) - Sale of Micafunign Sodium by the DTA unit of Appellant is covered under Serial No. 114 of Entry No. 180 of Rate Notification No 01/2017 CT (R) and therefore, is leviable to GST at the rate of 5%'....

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AAR allowed withdrawal of ruling application as relevant Venture was over

In re Savitri Ashirvaad Buildtech Limited (GST AAR Telangana) - In the reference 5th cited, M/s. Savitri Ashirvaad Buildtech Limited, have informed through mail, that the Venture is over and they don’t need the ruling.  Hence the dealer has withdrawn the advance Ruling Application....

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Supply of service by IZ Kartex to BCCL qualifies as import of service

In re IZ Kartex (GST AAAR West Bengal) - In re IZ Kartex (GST AAAR West Bengal) From the facts of the case, it is seen that the IZ-Kartex named after Korobkov, the Russian company has entered into the MARC with BCCL. They have deployed DDP-N, an Indian company as the subcontractor. DDP-N in turn, issues invoice to the Russian company. Agai...

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AAAR cannot answer on correctness of GST liability based on illustrative invoices

In re Apsara Co-operative Housing Society Ltd. (GST AAAR Maharashtra) - In re Apsara Co-operative Housing Society Ltd. (GST AAAR Maharashtra) The Maharasthra Appellate Authority for Advance Ruling upheld the Ruling passed by the Maharashtra Advance Ruling Authority, vide their Order No. GST-ARA-21/2019-20/B-34 dated 17.03.2020 and stated that the activities carried out ...

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Solid Waste Management services classifiable under SAC 9994

In re Zigma Global Environ Solutions Private Limited (GST AAR Tamilnadu) - In re Zigma Global Environ Solutions Private Limited (GST AAR Tamilnadu) Q. Classification of the services viz ‘Solid waste management – Revamping of existing dumped Garbage in compost yards by Bio -mining process’ provided by the applicant to M/s. Erode City Municipal Corporation...

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Guidelines for online e-hearing before GST AAR Maharashtra

Trade Circular ARA-01T of 2020 - (02/11/2020) - The Authority for Advance Ruling under Maharashtra Goods and Services Tax Act, 2017 will be conducting physical hearing of all applicants from its establishment at Mumbai, in respect of Advance Ruling Application filed by the said applicants....

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Advance Ruling Authority -MVAT

Notification No. VAT/AMD. 2015/1A/15/ADM-8 - (06/10/2020) - Commissioner of State Tax, Maharashtra State, hereby constitute the Advance Ruling Authority, comprising the following members : Shri Govind Vasantrao Bilolikar (CST-APP-F-002)...

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Attendance of jurisdictional officer for hearing of Advance Ruling

NO: GST/ARA/Maharashtra State/2018-19/B-49 Internal circular ARA No. 01/2019 - (03/04/2019) - Written submissions made by the concerned Officer /jurisdictional officer shall be approved by the jurisdictional Commissioner of Central Tax in case of CGST and Joint Commissioner of State Tax in case of SGST....

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CBDT amends Income Tax Advance ruling Forms

Notification No. 31/2018-Income Tax [G.S.R. 647(E) - (13/07/2018) - Income-tax (7th Amendment) Rules, 2018- CBDT seeks unique number for identification of non-resident- CBDT amends Forms for advance ruling -Notification No. 31/2018-Income Tax Dated 13th July, 2018 MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) Notification No. 31/2018-In...

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Details of officers designated as Rajasthan Appellate Authority for Advance Ruling

Trade Notice No. 04/2018 - (13/06/2018) - This Trade Notice is being issued to facilitate the Trade to know the details of the officers designated as the Rajasthan Appellate Authority for Advance Ruling constituted in terms Section 99 of the Rajasthan Goods & Service Tax Act, 2017, for the purpose of hearing appeals against the Advance Ruli...

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Recent Posts in "Advance Ruling"

5% GST on sale of Micafunign Sodium by DTA unit of BIOCON: AAAR

In re BIOCON Ltd. (GST AAR Karnataka)

Sale of Micafunign Sodium by the DTA unit of Appellant is covered under Serial No. 114 of Entry No. 180 of Rate Notification No 01/2017 CT (R) and therefore, is leviable to GST at the rate of 5%'....

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AAR allowed withdrawal of ruling application as relevant Venture was over

In re Savitri Ashirvaad Buildtech Limited (GST AAR Telangana)

In the reference 5th cited, M/s. Savitri Ashirvaad Buildtech Limited, have informed through mail, that the Venture is over and they don’t need the ruling.  Hence the dealer has withdrawn the advance Ruling Application....

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Supply of service by IZ Kartex to BCCL qualifies as import of service

In re IZ Kartex (GST AAAR West Bengal)

In re IZ Kartex (GST AAAR West Bengal) From the facts of the case, it is seen that the IZ-Kartex named after Korobkov, the Russian company has entered into the MARC with BCCL. They have deployed DDP-N, an Indian company as the subcontractor. DDP-N in turn, issues invoice to the Russian company. Again, the Russian […]...

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AAAR cannot answer on correctness of GST liability based on illustrative invoices

In re Apsara Co-operative Housing Society Ltd. (GST AAAR Maharashtra)

In re Apsara Co-operative Housing Society Ltd. (GST AAAR Maharashtra) The Maharasthra Appellate Authority for Advance Ruling upheld the Ruling passed by the Maharashtra Advance Ruling Authority, vide their Order No. GST-ARA-21/2019-20/B-34 dated 17.03.2020 and stated that the activities carried out by the Appellant would amount to supply ...

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Solid Waste Management services classifiable under SAC 9994

In re Zigma Global Environ Solutions Private Limited (GST AAR Tamilnadu)

In re Zigma Global Environ Solutions Private Limited (GST AAR Tamilnadu) Q. Classification of the services viz ‘Solid waste management – Revamping of existing dumped Garbage in compost yards by Bio -mining process’ provided by the applicant to M/s. Erode City Municipal Corporation, Erode?  A. Solid Waste Management-Rev...

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Nizam Pakku merits classification under Chapter 08028090

In re Shri Abdul Razak Safiullah (GST AAR Tamilnadu)

Shri Abdul Razak Safiullah (GST AAR Tamilnadu) Q. Whether the ‘Nizam Pakku’ bought and sold by the Applicant, the manufacturing process of which has been explained by them, is classifiable under Chapter heading 0802 8030 of the Customs Tariff and hence attract 2.5 % CGST as per Sl.No.28 of Schedule I of Notification 1/2017 Cen...

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Guidelines for online e-hearing before GST AAR Maharashtra

Trade Circular ARA-01T of 2020 (02/11/2020)

The Authority for Advance Ruling under Maharashtra Goods and Services Tax Act, 2017 will be conducting physical hearing of all applicants from its establishment at Mumbai, in respect of Advance Ruling Application filed by the said applicants....

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Advance Ruling for Unregistered Dealers (FORM GST ARA-01)

FAQs on Advance Ruling for Unregistered Dealers (FORM GST ARA-01) Q.1 Who can I apply for Advance Ruling? Ans: Application for Advance Ruling can be filed by any person who is registered or is desirous of obtaining registration under this Act on the matters prescribed under the GST Act with payment of the prescribed fee. […]...

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GST Advance Ruling filing & Tracking / Taking Action in Subsequent Proceedings

A. FAQs on Filing Applications Related to Advance Ruling and Tracking or Taking Action in the Subsequent Proceedings Filing an application (FORM GST ARA-01) for seeking Advance Ruling by Registered Taxpayers Q.1 Who can apply for Advance Ruling? Ans: An application for Advance Ruling can be made by any person who is registered or is [&hel...

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GST exempt on Supply of Kharif Arhar (Tur) & Green Grm crops to NAFED

In re The Karnataka State Co-Operative Marketing Federation Limited (GST AAR Karnataka)

In re The Karnataka State Co-Operative Marketing Federation Limited (GST AAR Karnataka) Q1. Whether the transaction of supplying Kharif Arhar (Tur) Crops and Green Grm crops from farmers to NAFED is a taxble supply ? What is the rate of tax to be charged for sale of Agricultural produce to NAFED, if it is to […]...

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Pure consultancy services to Municipalities & Corporations are exempt from GST

In re Vimos Technocrats Private Limited (GST AAR Karnataka)

In re Vimos Technocrats Private Limited (GST AAR Karnataka) Q1. Whether pure consultancy services provided to the Municipalities and Corporations are exempt from GST as per the serial number 3 of the notification 12/2017-Central tax (Rate) dated 28.06.2017? A1. Pure consultancy services (without supply of goods) provided by the applicant ...

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No ITC on medicines used in supply of health care services to inpatients

In re Ambara (GST AAR Karnataka)

In re Ambara (GST AAR Karnataka) Q1. Whether input tax credit is required to be restricted on medicines supplied to patients admitted in hospital? A1. The input tax credit is required to be restricted on medicines used in the supply of health care services provided to inpatients. Q2. Whether input tax credit is required to […]...

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GST on Liaison office in India of Foreign Company

In re Fraunhofer-Gessellschaft Zur Forderung der angewwandten Forschung (GST AAR Karnataka)

Whether the Activities of a liaison office amount to supply of services, Whether a liaison office is required to be registered under CGST Act, 2017 and Whether liaison office is liable to pay GST?...

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Contributions for DMF & NMET was directly linked to royalty & amounts to Supply

In re NMDC Limited (GST AAR Karnataka)

In re NMDC Limited (GST AAR Karnataka) The applicant filed the instant application, for rectification of ruling, alleging that the authority has not ruled in the order as to whether the contributions towards DMF & NMET amount to supply in terms of Section 7 of the CGST Act 2017 or not and also the authority […]...

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18% GST Payable on royalty paid in respect of Mining Lease

In re NMDC Ltd. (GST AAR Karnataka)

In re NMDC Ltd. (GST AAR Karnataka) 1. The royalty paid in respect of Mining Lease is a part of the consideration payable for the Licensing services for right to use minerals including exploration and evaluation falling under the Head 9973 which is taxable at the rate applicable on supply of like goods involving transfer […]...

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Printing content provided by customer on PVC banners is supply of Goods

In re Macro Media Digital Imaging Pvt Ltd (GST AAAR Karnataka)

(i) Whether the transaction of printing of content provided by the customer, on Poly Vinyl Chloride (PVC) banners and supply of such printed trade advertisement material is supply of goods. (i) The transaction of printing of content provided by the customer, on Poly Vinyl Chloride (PVC) banners and supply of such printed trade advertiseme...

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18% GST on street lighting activity under Energy Performance Contract

In re Karnataka State Electronics Development Corporation Limited (GST AAAR Karnataka)

i. The street lighting activity under the Energy Performance Contract dated 05-12-2016 is considered as a composite supply of goods and services with the supply of service being the predominant supply. The service is classified under Heading 999112....

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Period for filing appeal against AAR order to be counted from Original Order & not from date of ROM rejection order

In re NMDC Ltd (GST AAAR Karnataka)

In re NMDC Ltd (GST AAAR Karnataka) An appeal can be filed before the Appellate Authority only against an advance ruling pronounced in terms of Section 98(4). In this case, the ruling pronounced in terms of Section 98(4) is the advance ruling order No KAR ADRG 69/2019 dated 21-09-2019. An appeal is maintainable only against […]...

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Proportionate ITC on procurement of capital goods for power generation business can be claimed

In re Kumaran Oil Mill (GST AAR Tamilnadu)

In re Kumaran Oil Mill (GST AAR Tamilnadu) Whether proportionate claim of input tax credit for procurement of capital goods can be made for power generation business? The applicant is eligible for Proportionate claim of Input Tax Credit as per Section 17(2) of the CGST/TNGST Act read with Rule 42/Rule 43 of CGST/TNGST Rules 2017 […...

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GST on supply of Dress, School Bag, Boots etc to students without consideration to Govt/Govt Aided schools

In re Tamil Nadu Textbook and Educational Services Corporation (GST AAR Tamilnadu)

In re Tamil Nadu Textbook and Educational Services Corporation (GST AAR Tamilnadu) 1 & 2 Whether the supply of educational aids to students such as school bags, footwear, geometry box, wooden colour pencils, crayons, woollen sweater to government and government aided schools based on the State Government educational policy for which t...

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IIT Madras Alumni Association liable to Pay GST & Register under GST

In re IIT Madras Alumni Association (GST AAR Tamilnadu)

In re IIT Madras Alumni Association (GST AAR Tamilnadu) Q. Whether collecting money by IITMAA from its members and receiving donations/ grants/ subsidies/budgetary support from IIT, Madras to defray expenses incurred towards administering the association and other expenses related to its engagement activities initiated by members themselv...

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No GST on Supply of alcoholic liquor for human consumption by a restaurant

In re MFAR Hotels & Resorts Private Ltd. (GST AAR Tamilnadu)

In respect of Q.No.2, the applicant on rephrasing the original question has sought clarification on the taxability of alcoholic liquor for human consumption under GST when supplied in the restaurant. It is stated that they serve liquor in restaurants and room service. From the invoice furnished, it is seen that the applicant is charging o...

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GST on body building activity on a truck chassis made available by a customer

In re Tube Investments of India Ltd (GST AAR Tamilnadu)

In re Tube Investments of India Ltd (GST AAR Tamilnadu) Q. Whether the activity undertaken by the applicant amounts to supply of goods or supply of services. Whether the activity of building and mounting of the body on the chassis made available by the customers will result in supply of goods or supply of services. A. […]...

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GST on leasing of pathway to a person to her/his dwelling unit

In re Chennai Metro Rail Ltd. Ltd. (GST AAR Tamilnadu)

In re Chennai Metro Rail Ltd. Ltd. (GST AAR Tamilnadu) Whether leasing of pathway to a person to her/his dwelling unit by CMRL is taxable under GST? In the case at hand, the applicant owns the pathway but has agreed through an MOU with the individual to permit her to use the pathway to access […]...

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GST on Services related to testing of chemicals in fresh table grapes

In re SGS India Private Limited (GST AAR Tamilnadu)

In re SGS India Private Limited (GST AAR Tamilnadu) Whether the supply of “inspection and testing services” on fresh table grapes is classifiable under entry 9986 of Notification no.11/2017-Central Tax Rate) dated June 28 2017– “Support services to agriculture, forestry, fishing, animal husbandry” chargeable to NIL rate of t...

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GST on printing of content provided by customer on poly vinyl chloride banners

In re Macro Media Digital Imaging Private Limited (GST AAR Tamilnadu)

In re Macro Media Digital Imaging Private Limited (GST AAR Tamilnadu) Q1.Whether the transaction of printing of content provided by the customer, on poly vinyl chloride banners and supply of such printed trade advertisement material is supply of goods.? A1. The printing of content provided by the recipient on the PVC materials of the appl...

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GST on reimbursement of expenses to holding company located outside India

In re ICU Medical India LLP (GST AAR Tamilnadu)

In re ICU Medical India LLP (GST AAR Tamilnadu) Q1.Whether GST is leviable on the reimbursement of expenses from the Subsidiary Company to its ultimate holding company located in a foreign territory outside India. A1. The applicant is liable to pay IGST on the Wellsone Commercial Card’ expenses paid by the applicant to its Ultimate ...

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GST on Pre-mix popcorn maize (com kernels) packed with edible oil & salt

In re Gourmet Popcornica LLP (GST AAR Tamilnadu)

In re Gourmet Popcornica LLP (GST AAR Tamilnadu) Q1.What would be the accurate HSN code and consequently, the rate off GST applicable on pre-mix popcorn maize packed with edible oil and salt? Whether the same can be classified under HSN Heading 2008 and whether the same shall be chargeable to tax at the rate of […]...

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Marketable/consumable/Manufactured Chewing tobacco classifiable under CTH 24039910

In re Kavi Cut Tobacco (GST AAAR Tamilnadu)

In re Kavi Cut Tobacco (GST AAAR Tamilnadu) The appellant has stated to have purchased ‘Raw dried tobacco leaves’ from wholesale dealers/farmers and then undertakes the process of grading, drying, dipping in jaggery water, stalking, semi-drying, mincing, subjecting to natural/agricultural preservatives, weighing and packing fo...

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Person liable to pay consideration for supply of services is ‘Recipient’ of such supply

In re Rajesh Rama Varma (GST AAAR Tamilnadu)

In re Rajesh Rama Varma (GST AAAR Tamilnadu) Appellant has been contracted by M/s Doyen Systems Private Ltd to provide professional and consultancy services to be carried out through them and that, he had rendered software support services to the client of M/s Doyen Systems Private Ltd, IRM in the United States of America and […]...

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Milk with turmeric extracts is classifiable under HSN 0401

In re ITC Limited (GST AAR West Bangal)

Milk fortified with vitamins A and D is classifiable under HSN 0401. The above Explanatory Note further explains that such milk remains classified under HSN 0401 even if a small quantity of items containing anti-oxidant properties are added. The applicant's product, therefore, remains classifiable under HSN 0401 even after a small quantit...

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Works contract service of laying pipelines in Bangladesh is not export

In re Maninder Singh (GST AAR West Bengal)

In re Maninder Singh (GST AAR West Bengal) NRL has awarded the contract to the applicant for construction of the pipeline in Bangladesh and pays the consideration. NRL is, therefore, the recipient in terms of section 2(93)(a) of the GST Act. A strip of land extending over more than a hundred kilometre is not a […]...

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Impact on Valuation of used waste sand which is of the value ‘Nil

In re Kolhapur Foundry and Engineering Cluster (GST AAR Maharashtra)

In re Kolhapur Foundry and Engineering Cluster (GST AAR Maharashtra) The question raised by the applicant is ‘The used waste sand which is of the value NIL Refer separate Valuation Certificate by Engineer) will have any impact on Valuation?.’ The jurisdictional officer has submitted that, as regards the second question, valu...

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Renting of e-bikes/bicycles without operator cannot be classified under SAC 9973

In re Yulu Bikes Pvt. Ltd. (GST AAR Karnataka)

In re Yulu Bikes Pvt. Ltd. (GST AAR Karnataka) Renting of e-bikes/bicycles without operator cannot be classified under SAC 9973 – Leasing or rental services without operator and Sl.no. 17(viia) of Notification no. 11/2017 CT(R) dated 28th June 2017 as amended is not applicable to the instant case. FULL TEXT OF ORDER OF AUTHORITY OF ...

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Advance Ruling Authority -MVAT

Notification No. VAT/AMD. 2015/1A/15/ADM-8 (06/10/2020)

Commissioner of State Tax, Maharashtra State, hereby constitute the Advance Ruling Authority, comprising the following members : Shri Govind Vasantrao Bilolikar (CST-APP-F-002)...

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Advance ruling obtained by suppression of material facts is void ab initio

In re ID Fresh Food (India) Pvt. Ltd (GST AAAR Karnataka)

In re ID Fresh Food (India) Pvt. Ltd (GST AAAR Karnataka) We find that Section 100 of the CGST Act provides for an appeal to be filed by any party who is aggrieved by the advance ruling given by the lower Authority. In this case, the Department is not aggrieved by the ruling given by […]...

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GST on residential affordable housing project

In re Primarc Projects Pvt Ltd (GST AAR West Bengal)

In re Primarc Projects Pvt Ltd (GST AAR West Bengal) Whether the applicant is eligible for tax concession for its RREP named Akriti being an affordable housing project? The works contract service for the construction of those dwelling units in the project named ‘Akriti’ (WBHIRA Registration No. HIRA/P/PUR/2018/000003) that are...

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No GST on Prize money/ stakes in absence of any supply

In re Vijay Baburao Shirke (GST AAAR Maharashtra)

In re Vijay Baburao Shirke (GST AAAR Maharashtra) The Appellant Authority set aside the advance ruling issued by AAR, and hold that prize money/ stakes will not be subject to GST in the absence of any supply. Accordingly, the Applicant- Respondent is also not entitled to avail any ITC in accordance with the provisions of […]...

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Supply cannot be treated as Composite merely because it was based on Single Contract

In re Vertiv Energy Pvt. Ltd. (GST AAAR Maharashtra)

It is argued by the Appellant the supplies under the present case are not being made in the conjunction with each other, as the supply of services i.e. erection, commissioning, installation, testing etc. are undertaken only after the supply of the goods, i.e. UPS systems and other accessories, have been effected to the recipient of the go...

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AAAR rejects application for rectification as no apparent mistake in order

In re Micro Instruments (GST AAAR Maharashtra)

In re Micro Instruments (GST AAAR Maharashtra) The Appellate Authority for Advance Ruling, hereby, reject the application filed by the Appellant under section 102 of the CGST Act, 2017 seeking the amendment in the AAAR Order No. MAH/AAAR/SS-RJ/26/2018-19 dated 22.03.2019. since there is dispute in the interpretation of the legal provision...

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There cannot be two GTAs in single transportation of goods

In re Liberty Translines (GST AAAR Maharashtra)

In re Liberty Translines (GST AAAR Maharashtra) The Maharashtra Appellate Authority confirmed the Maharashtra Advance Ruling Autority Order by holding that  the activities of the Appellant would not be classified as GTA service under the Head 996791 as there cannot be two GTAs in the single transportation of the goods. FULL TEXT OF ORDER...

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Sale of TDR/FSI leviable to GST: AAAR

In re Vilas Chandanmal Gandhi (GST AAAR Maharashtra)

In re Vilas Chandanmal Gandhi (GST AAAR Maharashtra) The Maharashtra Appellate Authority confirmed the Maharashtra Advance Ruling Autority Order by holding that  the sale of TDR/FSI would be leviable to GST under Heading 9972, at the rate of 18% (9% CGST + 9% SGST), as prescribed under the entry at Sl. No. 16 (iii) of Notification [&hel...

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NO ITC to Co-Op Society on lift installation charges

In re Las Palmas Co-Op. Housing Society (GST AAAR Maharashtra)

In re Las Palmas Co-Op. Housing Society (GST AAAR Maharashtra) The Maharashtra Appellate Authority for Advance Ruling while upholding the ruling given by the Maharastra Advance Ruling Authority held that the Appellant will not be eligible to avail the ITC in respect of the lift installation charges paid to the lift contractor, in terms of...

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No GST on additional/Penal interest for delayed Loan EMI payment

In re Bajaj Finance Limited (GST AAAR Maharashtra)

In re Bajaj Finance Limited (GST AAAR Maharashtra) The Appellate Authority for Advance Ruling, hereby, hold that the additional/Penal interest recovered by the Applicant from their customers against the delayed payment of monthly instalments of the loan extended to such customers, would be exempt from GST in terms of Sl. 27 of the Notific...

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Tunnel construction & related work  falls under earth work & eligible for concessional GST rate

In re Soma Mohite Joint Venture (GST AAAR Maharashtra)

In re Soma Mohite Joint Venture (GST AAAR Maharashtra) The Maharashtra Appellate Authority for Advance Ruling  held that the services provided by the Appellant in the impugned matter qualifies for inclusion under entry 3(vii) of the Notification No. 12/2017-C.T. (Rate), dated 28.06.2017 (as amended by Notification No. 31/2017-C.T. (Rate)...

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No ruling can be given on questions not related to Appellant :AAAR

In re Kasturba Health Society (GST AAAR Maharashtra)

In re Kasturba Health Society (GST AAAR Maharashtra) The Maharashtra Appellate Authority for Advance Ruling  held that the  questions by the Appellant are not maintainable in terms of the Clause (a) of section 95 of the CGST Act, 2017, as the transaction with respect to which the Appellant has asked the questions, are not pertaining [&h...

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Gaming zone operated in mall premises attracts 28% GST

In re Bandai Namco India Private Limited (GST AAAR Maharashtra)

In re Bandai Namco India Private Limited (GST AAAR Maharashtra) The Appellate Authority for Advance Ruling, hereby, uphold the ruling pronounced by the Advance Ruling Authority, wherein it was held that the gaming zone operated by the Appellant in the mall premises would attract GST at the rate of 28% (CGST @ 14% + SGST@ […]...

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AAAR cannot determine if Supply of services amounts to export or not

In re Mayank Jain (GST AAAR Maharashtra)

In re Mayank Jain (GST AAAR Maharashtra) Once it has been decided that the entire gamut of activities of the Appellant, which are in the nature of the facilitation of the main services between the Consultant Manager and its customers, i.e. prospective investors, are those of an intermediary, we proceed to the determination of the [&hellip...

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28% GST Payable on Supply of Air Conditioners with Installation Services

In re Nikhil Comforts (GST AAAR Maharashtra)

In re Nikhil Comforts (GST AAAR Maharashtra) The Maharashtra Appellate Authority for Advance Ruling while confirming the order of the Maharashtra Advance Ruling Authority held that the contract in the impugned case is though a composite supply not for immovable property, and therefore does not fall under the definition of ‘works contrac...

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Breakwater not Plant & Machinery- ITC not eligible- AAAR

In re Konkan LNG Private Limited. (GST AAAR Maharashtra)

In re  Konkan LNG Private Limited. (GST AAAR Maharashtra) The Maharashtra Appellate Authority confirmed the Maharashtra Advance Ruling Autority Order by holding that  the Appellant is not eligible for taking ITC in terms of section 16  read with section 17  of the MGST ACT / CGST ACT ( CGST/ SGST / IGST ) on construction […]...

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Supreme Court urges for a vibrant & ‘redeveloped’ Advance Ruling System

Earlier this month, the Supreme Court adjudicated a 44-year old case pertaining to Finance Year 1975-76, in the case of National Co-Operative Development Corporation (a government corporation set up under the National Development Corporation Act). While concluding, the Court remarked on the present system of tax litigations that the Supre...

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Section 122 penalty cannot be imposed for violation of anti-profiteering provisions

Sh. Saurabh Gahoi Vs. Pinky Sales (NAA)

Sh. Saurabh Gahoi Vs. Pinky Sales (NAA) it has been revealed that the Respondent had not passed on the benefit of rate reduction when the rate of GST was reduced from 18% to 5% on foot wear, as per the provisions of Section 171 (1) of the CGST Act, 2017 for the period w.e.f. 27.07.2018 […]...

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GST can be levied on notional interest on security deposit: AAR

In re Midcon Polymers Pvt. Ltd. (GST AAR Karnataka)

Notional interest has to be considered as part of value of supply of service, if and only if the said notional interest influences the value of supply i.e. value of RIS service / monthly rent and is leviable to GST along with monthly rent at the rate applicable to monthly rent....

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No GST on Scanning of answer sheets for educational institution

In re Datacon Technologies (GST AAR Karnataka)

In re Datacon Technologies (GST AAR Karnataka) Applicant were awarded a contract by the Bihar School Educational Board (BSEB) vide Work Order No. ST/281/18 DT dated 16.12.2018 for scanning of OMR Flying slip, OMR Marks Foil, OMR attendance sheet, OMR absentee sheet and finalisation of data. In view of the above, the applicant sought Advan...

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Land filling Pit is not a plant & machinery but a civil structure

In re Mother Earth Environ Tech Pvt Ltd. (GST AAR Karnataka)

Civil structure involves engineering work at both levels i.e above and below the ground. We find that the applicant has performed civil work to create the landfill pits below the ground and therefore it is a civil structure....

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GST on services provided by Housing Society to Members

In re Gnanaganga Gruha Nirmana (GST AAR Karnataka)

In re Gnanaganga Gruha Nirmana (GST AAR Karnataka) 1. The activity of maintaining the facilities at the layout from the funds collected from the members of the Society is a service attracting GST. The answer is Yes. 2. The contributions collected by the applicant from the member of the housing society either annually or once […]...

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All About Advance Ruling Authority Under GST

All about Advance Ruling under GST i.e. Section 95 to Section 106 of the CGST Act, 2017 Article explains Basic understanding of Advance Ruling, The broad objectives for setting up a mechanism of Advance Ruling, Applicability of Advance Ruling, Authority for Advance Ruling (AAR) & Appellate Authority for Advance Ruing (AAAR), Questions...

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No Bar U/s. 245R(2)(i) merely due to notice asking applicant to produce any evidence in support of its return

CIT Vs Authority for Advance Ruling Income Tax (Delhi High Court)

CIT Vs Authority for Advance Ruling (Delhi High Court) The issue under consideration is whether the question raised in the notice under Section 143(2) can be stated to be ‘pending’ to attract clause (i) of the proviso to Section 245R(2) of the Act? In the present case, the petitioner i.e CIT argues that since the […]...

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ITC on Lift available or not under GST

Lift is not a machine , it is part of Building, is it true . is the ITC claimable on purchase of Lift . Let us discuss whether lift is machine or Building only we would reach to conclusion of ITC is eligibility. Section 17(5) blocks credit of works contract and goods or services received […]...

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HSN Code & GST rate for Plastic Mechanical Liquid Dispenser

In re Nishith Vipinchandra Shah (GST AAR Gujarat)

In re Nishith Vipinchandra Shah (GST AAR Gujarat) Question: What is the HSN Code and rate of tax for Plastic Mechanical Liquid Dispenser? Answer: Imported Plastic Items, (stated as Plastic Mechanical Liquid Dispenser) shall be classified, under HSN Chapter sub-heading 3926.90- Others, as ‘articles, not elsewhere specified or include...

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GST: Value of supply on sale property with undivided rights of land

In re Karma Buildcon (GST AAR Gujarat)

In re Karma Buildcon (GST AAR Gujarat) Question 1. What will be the value of supply for the transaction of sale of residential/ commercial property with undivided rights of land? Answer : The value to be arrived in terms of deeming provision of Para 2 of Notification no. 11/2017-CT (Rate) dated 28.06.2017, as amended by […]...

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GST on Licensing services for right to use minerals including its exploration & evaluation

In re Giriraj Quarry Works (GST AAR Gujarat)

In re Giriraj Quarry Works (GST AAR Gujarat) (i) What is the classification of service provided in accordance with Notification 11/2017-CT (Rate) dated 28.06.2017 read with annexure attached to it, , for which royalty is being paid. Ans. The activity undertaken by the applicant is classifiable under Heading 9973 (Leasing or rental service...

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GST payable on service for maintenance of accounts to SSNNL

In re Dhirubhai Shah & Co. LLP (GST AAR Gujarat)

In re Dhirubhai Shah & Co. LLP (GST AAR Gujarat) The professional service for maintenance of accounts and allied items of work provided to  SardarSarovar Narmada Nagar Limited (SSNNL ) { A Government of Gujarat undertaking) by the applicant is a taxable service under Section 9 (1) of The CGST Act, 2017 or exempted vide […]...

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GST on body building on chasis of motor vehicle owned by others

In re AB N Dhruv Autocraft (India) Pvt. Ltd (GST AAR Gujarat)

In re AB N Dhruv Autocraft (India) Pvt. Ltd (GST AAR Gujarat) A. Whether the treatment or process of body building by fabrication and other processes carried out on chasis of motor vehicle owned by others is supply of services? Ans. In case the applicant received the chasis from the principal on Job work challan/ […]...

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Maize Bran cannot be considered as a ‘cattle feed’ by definition

In re Sayaji Industries Ltd. (GST AAR Gujarat)

In re Sayaji Industries Ltd. (GST AAR Gujarat) Maize Bran is used as a major supplement for cattle feed. The word ‘supplement’ is defined in dictionary as “a thing added to something else in order to complete or enhance it.” Therefore, Maize Bran is a product which is added to cattle feed to complete it […]...

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GST registration applicability to franchisees of taxable person

In re Patrator (GST AAR Gujarat)

In re Patrator (GST AAR Gujarat) On going through the said clauses of the agreement, it is observed that the applicant is required to fulfill the requirements of infrastructure and manpower before commencement of operations of the Centre as per the instructions of the Company and will continue to possess it during the whole tenure [&helli...

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GST on educational assessment examination services to school

In re Educational Initiative Pvt. Ltd. (GST AAR Gujarat)

In re Educational Initiative Pvt. Ltd. (GST AAR Gujarat) (i) Whether the educational assessment examination (ASSET) with its variants) provided by the applicant to school/educational organization is exempted from payment of GST under Sr. No. 66(b)(iv) of the Not. No. 12/2017-CT (rate) dated 28.06.2017 and entry No. 69(b)(iv) of Not. No. 9...

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GST payable on Supply of residential flats before date of completion certificate

In re V 2 Realty (GST AAR Gujarat)

In re V 2 Realty (GST AAR Gujarat) Question 1. Whether selling of residential flats after date of completion certificate of commercial shops or after first occupancy in building is exempt supply? Ans. During the personal hearing, the applicant himself stated that they didn’t receive Completion Certificate in respect of their residential...

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GST exemption to Nimba Nature Cure Village on Naturopathy services

In re Oswal Industries ltd.( M/s. Nimba Nature Cure Village) (GST AAR Gujarat)

In re Oswal Industries ltd.( M/s. Nimba Nature Cure Village) (GST AAR Gujarat) The applicant M/s. Oswal Industries ltd. (M/s. Nimba Nature Cure Village) is not eligible to get the benefit of entry No.74 of exemption Notification No.12/2017-Central Tax (Rate) dated 28.06.2017. FULL TEXT OF ORDER OF AUTHORITY OF ADVANCE RULING, GUJARAT The ...

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5% GST Payable on ‘Maize Bran’: GST AAR Gujarat

In re Gujarat Ambuja Exports ltd. (GST AAR Gujarat)

In re Gujarat Ambuja Exports ltd. (GST AAR Gujarat) The product ‘Maize Bran’ manufactured and supplied by M/s. Gujarat Ambuja Exports ltd. is covered under Entry Sr.No.103A of Notification No.1/2017-Central Tax (Rate) dated 28.06.2017 of the CGST Act, 2017 on which rate of GST chargeable is 5% (2.5% SGST + 2.5% CGST). FULL TEXT OF [&h...

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12% GST Payable on Products ‘Rhyzomyx’ & ‘Rhyzomyco’

In re Novozymes South Asia pvt.ltd (GST AAR Gujarat)

In re Novozymes South Asia pvt.ltd (GST AAR Gujarat) The products ‘Rhyzomyx’ and ‘Rhyzomyco’ manufactured and supplied by M/s. Novozymes South Asia pvt. ltd., is covered under Entry Sr.No.61 of Schedule-II of Notification No.1/2017-Central Tax (Rate) dated 28.06.2017 of the CGST Act, 2017 on which rate of GST chargeable is 12% (6%...

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Micromanipulator System falls under Tariff item no. 9011

In re Shivani Scientific Industries (GST AAR Gujarat)

In re Shivani Scientific Industries (GST AAR Gujarat) The product ‘Micromanipulator system’ manufactured and supplied by M/s. Shivani Scientific Industries pvt.ltd. is classifiable under Tariff item no. 9011 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975).   The said product  is covered under Entry No. 184 of Sch...

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GST on reimbursement of Fuel Charges in the course of rental services of aircraft

In re Global Vectra Helicorp ltd. (GST AAR Gujarat)

In re Global Vectra Helicorp ltd. (GST AAR Gujarat) In terms of the valuation provisions under GST legislation, amount recovered as reimbursement (at actual) by the applicant M/s. Global Vectra Helicorp ltd. from the customer, for the fuel procured on behalf of the Customer is required to be included in the value of services provided by ...

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‘Fly Ash Bricks’ classifiable under Tariff item No. 68159910

In re Dipakkumar Ramjibhai Patel (GST AAR Gujarat)

In re Dipakkumar Ramjibhai Patel (GST AAR Gujarat) Whether supply of Fly Ash Bricks and Fly Ash Blocks are covered under Chapter heading 68159090 and liable to taxed @ 5% and @ 12% respectively under the GST Act? (1) The product ‘Fly Ash Bricks’ manufactured and supplied by Dipakkumar Ramjibhai Patel (M/s. Mahalaxmi Cement pro...

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Sprayer pumps (manually operated) falls under HSN 84248100

In re Adarsh Plant Protect ltd. (GST AAR Gujarat)

In re Adarsh Plant Protect ltd. (GST AAR Gujarat) Determination of the liability to pay tax on any goods or services or both.( ‘Sprayer pumps’ (manually operated), Stoves) (1) The product ‘Sprayer pumps’ (manually operated) manufactured and supplied by M/s. Adarsh Plant Protect ltd. are classifiable under Tariff item No.84...

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GST under RCM on salary to Directors- AAR allowed application withdrawal

In re Man Structurals (P) Ltd. (GST AAR Rajasthan)

In re Man Structurals (P) Ltd. (GST AAR Rajasthan) Whether GST is payable under Reverse Charge Mechanism (RCM) the salary paid to Directors of the company who is paid salary as per employment contract? We observe that Shri Madhu Sudan Sharma, authorized representative of the applicant, submitted a letter dated 29.06.2020 addressed to this...

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GST on Tour Operator services to Main Tour Operator

In re Crown Tours & Travelers (GST AAR Rajasthan)

In re Crown Tours & Travelers (GST AAR Rajasthan) Whether the rate of 5% under heading 9985(i) is applicable on transaction which the Applicant intents to undertake wherein a single invoice is raised in respect of all the services i.e. local transportation services along-with services like sightseeing, tour guide, elephant ride etc., ...

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ITC restriction against diagnostic or investigative services

In re Siddalingappa Palalochana Rakshit (Bangalore Medical System) (GST AAR Karnataka)

In re Siddalingappa Palalochana Rakshit (Bangalore Medical System) (GST AAR Karnataka) In the instant case the applicant established a medical diagnostic laboratory to carry out diagnostic or investigative services of diseases. Thus the applicant qualifies to be a clinical establishment. It is clear, from the foregoing, that the services ...

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Shiva Parvathi Theater guilty of not passing GST reduction benefit: NAA

Principal Commissioner Vs Shiva Parvathi Theatre 70 MM (NAA)

Principal Commissioner Vs Shiva Parvathi Theatre 70 MM (NAA) The main issues to be examined in the present matter were whether the GST rate on Services by way of admission to exhibition of cinematography films where price of admission ticket is above one hundred rupees” was reduced from 28% to 18% w.e.f. 01.01.2019 and Services [&he...

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Inox Leisure Guilty of Profiteering: NAA

Principal Commissioner Vs Inox Leisure Ltd. (NAA)

The main issues to be examined in the present matter were whether the GST rate on Services by way of admission to the exhibition of cinematograph films where the price of admission ticket was above one hundred rupees was reduced from 28% to 18% w.e.f. 01.01.2019...

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GST payable on leasing of property in the nature of hotel, inn, guest house

In re Sri. Taghar Vasudeva Ambrish (GST AAAR Karnataka)

We find that the Appellant has constructed the building with the intention of providing hostel accommodation which is more akin to sociable accommodation rather than what is commonly understood as residential accommodation. Therefore, we conclude that the impugned property cannot be termed as residential dwelling. Once the impugned proper...

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AAR application dismissed as investigation was already initiated

In re Tirumala Milk Products Pvt. Ltd. (GST AAR Karnataka)

In re Tirumala Milk Products Pvt. Ltd. (GST AAR Karnataka) In the instant case, the Deputy Commissioner, Office of the Principal Commissioner of Central Tax, Bangalore East Commissionerate, Bangalore have reported vide their letter dated 18.08.2020 that the Directorate of GST Intelligence, Bangalore Zonal Unit have initiated the investiga...

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No GST on Transportation charges recovered from employees

In re Tata Motors Limited (GST AAR Maharashtra)

Whether GST is applicable on nominal amount recovered by Applicants from their employees for usage of employee bus transportation facility in non-air conditioned bus....

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Whether supply of tour operator services is Ancilliary Services & covered under 18%

Advance Ruling  Name of the Applicant:- M/s Crown Tour and Travels Advance Ruling No. :- RAJ/AAR/2019-20/25 Date Of Ruling :- 26/11/2019 Brief facts of case:- The application in business of providing Tour Operator as well Support Services in particular set of transactions, the Applicant received service orders from the main tour operator...

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Advance Ruling | Sec 10(1)(a) & 10(1)(b) of IGST Act 2017

As I promised in previous post related to GST Registration requirement, If covered under bill to ship to model?  That I will provide the solutions relating to Litigation posted in previous post on sec 10(1)(a) and 10(1)(b). However, Following Advance Ruling covered same litigation as we already discussed in our previous post, that provid...

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Latex collection cup used for rubber tapping is an agricultural implement

In re Tainakathuveettil Appukuttan Dayanandan (M/s. Sun Polymers) (GST AAR Kerala)

In re Tainakathuveettil Appukuttan Dayanandan (M/s. Sun Polymers) (GST AAR Kerala) The process of collection of rubber latex through rubber tapping is an agricultural activity. Plastic cups are used to collect latex from rubber trees. The plastic cups are placed below the spouts using cup hangers. The applicant is engaged in the manufactu...

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Plastic latex collection cup comes under HSN 8201 90 00

In re Matha Timber Industries (GST AAR Kerala)

In re Matha Timber Industries (GST AAR Kerala) The process of collection of rubber latex through rubber tapping is an agricultural activity. Plastic cups are used to collect latex from rubber trees. The plastic cups are placed below the spouts using cup hangers. The applicant is engaged in the manufacture and supply of plastic cups, [&hel...

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GST on Plastic cups used to collect latex from rubber trees

In re Thadickal Trading Company (GST AAR Kerala)

In re Thadickal Trading Company (GST AAR Kerala) The process of collection of rubber latex through rubber tapping is an agricultural activity. Plastic cups are used to collect latex from rubber trees. The plastic cups are placed below the spouts using cup hangers. The apphcant is engaged in the wholesale and retail supply of plastic [&hel...

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GST on construction of Jetty & development of sites for N.T.R.O. on Deposit Work terms

In re Cochin Port Trust (GST AAR Kerala)

In re Cochin Port Trust (GST AAR Kerala) 1. Whether, having regard to the background and details including the scope of work of the Deposit work contained in the M.O.U. entered into between CoPT and N.T.R.O., what is the nature of the services rendered by CoPT under the M.O.U. entered Into between CoPT and N.T.R.O.? […]...

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GST exempt on Plastic latex collection cup used for collection of rubber latex

In re Pala Marketing Co-operative Society Ltd. (GST AAR Kerala)

In re Pala Marketing Co-operative Society Ltd. (GST AAR Kerala) Classification and rate of tax of agricultural implements namely latex collection cup, made of plastic, used exclusively for collection of rubber latex, an agricultural activity. Plastic latex collection cup is an agricultural implement exclusively used for rubber tapping and...

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Silicone Insole and Heel Cushion classifiable under HSN 6406

In re Dynamic Techno Medicals Pvt. Ltd. (GST AAR Kerala)

In re Dynamic Techno Medicals Pvt. Ltd. (GST AAR Kerala) The Silicone Insole and Heel Cushion are rightly classifiable under HSN 6406 [Parts of footwear (including uppers whether or not attached to soles other than outer soles); removable in-soles, heel cushions and similar articles; gaiters, leggings and similar articles, and parts there...

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Agricultural implements used for collection of rubber latex is exempt from GST

In re Zodiac Plastics (GST AAR Kerala)

In re Zodiac Plastics (GST AAR Kerala) Plastic latex collection cup is an agricultural implement exclusively used for rubber tapping and comes under the classification HSN 8201 90 00 ‘other hand tools of the kind used in agriculture, horticulture or forest’. As such it is exempted from GST as per SI No. 137 of Notification [&h...

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GST on institute imparting education to CA, CS, CMA, CPA students

In re Logic Management Training Institutes Pvt. Ltd. (GST AAR Kerala)

M/s. Logic Management Training Institutes Pvt. Ltd. is an institute imparting education to students to facilitate them in obtaining qualifications like Chartered Accountancy, Cost Accountancy, Company Secretary, Certified Management Accountant, Certified Public Accountant, Association of Chartered Certified Accountant etc. The applicant r...

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Services to Kerala Govt for integrated water transport project is exempted from GST

In re Kochi Metro Rail Limited (GST AAR Kerala)

In re Kochi Metro Rail Limited (GST AAR Kerala) The services rendered by the applicant to the Government of Kerala as executing and operating agency of the integrated water transport project is exempted from GST. 1. Since the Govt, of Kerala is the dejure owner of the assets of the water metro project and the […]...

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Analysis of Order of Karnataka AAAR in the case of M/s Karnataka Food & Civil Supplies Corporation

Recently, Karnataka AAAR in order number KAR /AAAR-14-I/2019-20 held that the services provided by Central Warehousing Corporation (CWC) are covered under ‘Rental or leasing services involving own or leased non-residential property’ and not under ‘storage and warehousing service’ and hence exemption is not available under entry no...

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AAR in case of M/s Pratham Agro vet Industries – GST Tariff on Rice Bran

AAR in case of M/s Pratham Agro vet Industries – GST Tariff on Rice Bran Question on which advanced ruling had been sought: What is the GST Tariff on Rice Bran obtained by processing Rice husk of Poha and Mamra with different kind sludge/wax oil What is Rice Bran: Rice Bran is a product obtained […]...

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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)

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 […]...

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GST on Security Excise Adhesive Labels

In re Marketing Communication & Advertising Ltd. (GST AAR Karnatka)

In re Marketing Communication & Advertising Ltd. (GST AAR Karnatka) The applicant have sought advance ruling  in relation to supply by applicant to various distilleries and sought ruling on correct classification of Security Excise Adhesive Labels i.e., HSN Code applicable and The rate of tax applicable on supply of Security Excise A...

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AAR allows S.K. Properties to withdraw advance Ruling application

In re M/s S.K. Properties (GST AAR Karnataka)

In re M/s S.K. Properties (GST AAR Karnataka) 1. The applicant sought Applicability of GST on Land owners share of constructed residetail flats, since Joint development agreement entered between Land owner and Builder entered before the commencement of construction of the building and Constructed residential flats handed over before compl...

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