2026-VIL-69-AAR
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SGST Advance Ruling Authority

GST – Tamil Nadu AAR - E-commerce Operator - The applicant operates an e-commerce platform that connects vehicle owners/drivers (transporters) with customers who require transportation services for their goods. Customers can book transporters through the online portal or mobile app of the applicant - Whether the applicant satisfies the definition of an "E-commerce operator" or "Goods Transport Agency" – HELD - The applicant satisfies the definition of an 'e-commerce operator' under the GST Act as it owns, operates and manages a digital platform for facilitating the supply of transportation services between transporters and customers. The applicant does not satisfy the definition of a 'Goods Transport Agency' as it is not involved in the actual transportation of goods by road, issuance of consignment notes or other ancillary activities. Though the service is ‘transportation of goods’, the supply of such service is through electronic platform. Therefore, the applicant qualify as an e-commerce operator - In addition to paying GST on the commission received from the transporters, the applicant, as an e-commerce operator, is required to follow the provisions of Section 52 of the CGST Act which mandate the collection of 'Tax Collected at Source' (TCS) at the rate specified by the Government notifications on the net value of taxable supplies made through the applicant's platform by the transporters. The applicant cannot be considered as a 'pure agent' for the limited purpose of collecting the entire transportation charges from customers and remitting the balance to the transporters, as the conditions specified in Rule 33 of the CGST Rules are not fulfilled – Ordered accordingly
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