2025-VIL-210-AAR
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SGST Advance Ruling Authority

GST – West Bengal AAR - Classification of transportation services, GTA services - Applicant is engaged in B2B trading of goods, proposed to implement a new business model wherein it would provide transportation services of goods exclusively by road to customers purchasing such goods from various e-commerce operator (ECO) portals. Under this model, the applicant would collect the goods from a designated "Source Mother Hub" and deliver them to the address specified by the end-customer at the time of purchasing goods on the ECO's portal. The transportation activity may involve multiple transit points and the applicant proposed to issue a single consignment note from the Source Mother Hub to the Delivery Address - Whether the services provided by the applicant to customers would qualify as "Goods Transport Agency" (GTA) services – HELD - The applicant is a "person" as defined under the GST Act and is providing the service of transporting goods exclusively by road - The applicant will issue a consignment note containing all the required details, which is a sine qua non for classification as a GTA as per the settled judicial precedents - The scope of GTA services includes not only the actual transportation of goods, but also any intermediate/ancillary services provided in relation to such transportation, such as loading/unloading, packing/unpacking, trans-shipment, temporary warehousing etc. Therefore, the services provided by the applicant to customers would qualify as "Goods Transport Agency" services. The authority also held that the ancillary services provided by the applicant, such as loading/unloading, packing/unpacking, transshipment, and temporary warehousing, in the course of transportation of goods, will be treated as part of the composite supply of GTA services – Ordered accordingly - Whether the services provided by the applicant to unregistered customers through the e-commerce operator's portal would be eligible for exemption in terms of Sl. No. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 – HELD - The transportation services provided by the applicant, being a GTA, to unregistered customers/recipients who order goods through the ECO's portal would be eligible for the exemption under Sl. No. 21A of the Notification - Since the applicant is a GTA, the services provided by it to unregistered recipients (individual customers) would be covered by the exemption - As per the proposed model, the end-customer is the recipient of the transportation services provided by the applicant and would be liable to pay the consideration for such services. The incidental/ancillary services provided by the applicant in the course of transportation of goods would also be covered under the said exemption as per the clarification issued by the CBIC.
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