2026-VIL-16-AAR
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SGST Advance Ruling Authority

GST – Tamil Nadu AAR - Classification of transportation services of goods exclusively by road to customers purchasing such goods from various e-commerce operator (ECO) portals - Whenever goods are purchased by customers through the ECO portal, the seller would deliver the goods to the applicant's nearest warehouse (Source Mother Hub), and the applicant would then issue a consignment note and transport the goods by road to the customer's delivery address - Whether the services provided would qualify as "Goods Transport Agency" (GTA) services – HELD - As per the definition of "goods transport agency" under the GST law, for any person to be termed as a GTA, two conditions must be cumulatively satisfied: (a) there must be provision of service in relation to transportation of goods by road, and (b) the service provider must issue a consignment note. The applicant is providing the service of transporting goods by road to the customers and issuing a consignment note, thereby fulfilling both the conditions. The issuance of a consignment note signifies that the responsibility of the goods lies with the GTA until delivery, and it acts as legal evidence of receipt of goods for transportation and transfer of custody from the consignor to the transporter. Accordingly, the applicant's activity of transporting the goods ordered through the e-commerce portal to the customer by road, upon issuance of a consignment note, would qualify as "Goods Transport Agency (GTA) services" – Ordered accordingly - Whether the services provided to unregistered customers through the ECO's portal would be eligible for exemption under Sl. No. 21A of Notification No. 12/2017 - Central Tax (Rate) - HELD – The Sl. No. 21A of Notification No. 12/2017 - Central Tax (Rate) provides exemption from GST for services provided by a GTA to an unregistered person, including an unregistered casual taxable person, subject to certain exclusions. Any person ordering goods through an e-commerce portal, if not registered under GST, would be eligible for this exemption on the GTA services provided to them. Accordingly, the services provided by the applicant to unregistered customers who order goods through the electronic commerce operator's portal are eligible for exemption in terms of entry Sl. No. 21A of Notification No. 12/2017 - Central Tax (Rate).
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