Rulings by Advance Authorities

Sl. NO.	Name of Applicant	Name of State/UT	Question(s) on which Advance Ruling Sought	Order No. & Date	View	Category as per Section 97(2) of SGST Act
41	Medpiper Technologies Pvt Ltd	Karnataka	a. Whether the assesse need to collect GST on the diagnostic and lab services provided through third party diagnostic labs? If yes, Whether GST has to be collected for the whole invoice amount or on the margin on the supply alone and what will be the applicable tax rate and which SAC to be used? b. Whether TCS needs to be collected? c. Whether the assesse fall under the definition/meaning of an “Insurance Agent” if invoiced to an insurance company, If yes how is GST applicable?	40 dated 13-11-2024	View	97(2)(a), 97(2)(b), 97(2)(c),97(2)(e)
40	S Residences	Karnataka	Whether the exemption given vide entry No.12 of Notification No.12/2017- Central Tax (Rate) dated 28.06.2017, as amended from time to time, is applicable to the hostel service given by the applicant?	40 dated 13-11-2024	View
39	Globe Moving and Sorage Pvt Ltd	Karnataka	Whether the supply of pure service made by our organization, (being a GTA-cum- Packing & Moving Company) to or on behalf of a foreign entity unregistered in India (unregistered person), is exempt from charge of GST under Notification No.32/2017- Central Tax (Rate) dated 13-10-2017 (entry number 21A) & amp; IGST Notification No.33/2017-IGST(Rate) dated 13-10-2017 (entry number 22A) ?	39 dated 06-11-2024	View	97(2)(b)
38	Uber India Systems Pvt Ltd	Karnataka	a. Whether the Applicant satisfies the definition of an e-commerce operator and the nature of supply as conceptualized in Section 9(5) of CGST Act, 2017 read with notification No.17/2017 dated 28.06.2017? b. Whether the Applicant is liable to collect and pay GST on the supply of services supplied by the drivers/service provider (person who has subscribed to online Uber platform in relation to proposed business model) to their customers (person who has subscribed to online Uber platform) identified on the Uber’s platform) under the proposed business model?	38 dated 04-11-2024	View	97(2)(b),97(2)(e),97(2)(g)
37	Criyagen Agri & Biotech Pvt Ltd	Karnataka	what is the HSN code and GST rates applicable to our new products by name Total-20-/F-20 Soil Application, Total-20-/F-20 (WSG), PH-50/Potassium Humate Granules, BO'N and Amigo-G?	37 dated 28-10-2024	View
36	Roppen Transportation Services	Karnataka	a. Whether the Applicant satisfies the definition of an e-commerce operator and the nature of supply as conceptualized in Section 9(5) of CGST Act, 2017 r/w notification No 17/2017 dated 28.06.2017? b.Whether the supply by the independent four-wheeler cab service provider (person who has subscribed to ‘Rapido’ app) to his passengers (who do not pay any subscription fee) on the app platform amounts to supply by the Applicant? c. Whether the Applicant is liable to pay GST on the supply of services provided by the independent four-wheeler cab service provider (person who has subscribed to applicant’s ‘Rapido’ app) to his passengers on the Applicant’s app platform? d.What is the rate at which GST shall be collected on the ride monitoring fee and the SAC code that shall be applicable? e. Whether the Applicant is liable to pay GST on the supply of services provided by the independent three/two-wheeler cab service provider (person who has subscribed to applicant’s ‘Rapido’ app) to his passengers on the Applicant’s app platform?	36 dated 24-07-2024	View	97(2)(b), 97(2)(e), 97(2)(g)
35	Raibag Taluk MSPC	Karnataka	a)    Whether exemption is available to the applicant as per S.N.66 clause (b)(ii) of notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 b) Whether “as per circular No. 149/05/2021- GST dated: 17.06.2021 and Entry 66 clause (b)(ⅱ) of notification No. 12/2017- central tax (Rate) dated 28.06.2017-central Tax (Rate) dated 28.06.2017, exempt services provided to an educational institution by way of catering, including any mid-day meals scheme sponsored by the Central Government, State Government or Union Territory. This entry applies to pre-school and schools’ is exemption available to the applicant. c) Whether clarification as per clarification No: KSA/GST.CR-05/2029-20 dated: 23rd June 2021 is applicable to the applicant. d) Whether Product Pushti supplied by the applicant not considered as pre-packaged and labeled” product and not taxed as per Notification 07/2022 Central Tax (Rate) dated: 13th July 2022 read with No. 78 of Notification 02/2027 Central Tax (Rates) dated 28th June 2017. e) Whether Product Pushti supplied by the applicant considered as “pre-packaged and labeled” product and taxed as per Notification 06/2022 Central Tax (Rate) dated: 13th July 2022 read with No. 59 of Notification 01/2017 Central Tax (Rate) dated: 28th June 2017.	35 dated 22-07-2024	View	97(2)(e) and 97(2)(b)
34	SRINIVAS PLYWOODS	Karnataka	a.    Input eligibility on renting of commercial Property. b. Applicability of RCM on freight inward. c. How to set off Input and Output in a situation where the Applicant is having more than one business done under the same GST Number?	34 dated 02-07-2024	View	97(2)(e) and 97(2)(d)
33	KSF-9 CORPORATE SERVICES PRIVATE LIMITED	Karnataka	1.Whether the Bruhat Bengaluru Mahanagra Palike, Banglore are exempt from GST for obtaining security services on outsource basis from security agency as per the pure services under 12th schedule to Article 243-W of the Constitution and under 11th schedule to Article 243-G?	33 dated 02-07-2024	View	97(2)(e)
32	K A SUJIT CHANDAN	Karnataka	Whether rent received from the Department of Social Welfare is taxable or not?	32 dated 02-07-2024	View	97(2)(e)
31	Fidelity Information Services India Private Limited	Karnataka	The Company recovers joining bonus and retention bonus on account of employee’s inability to serve the organization (or a particular department, in case of retention bonus) for a pre-agreed period. The applicant wishes to seek clarity whether GST would be applicable on recovery of such bonus? ii. Whether GST would be applicable on recovery of work from home one-time setup allowance paid to employees in case where the employees exit before serving the pre-defined period from the payout date? iii. Whether GST would be applicable on recovery of amount paid as financial assistance to employees under Tuition Assistance Program (TAP) policy in case where the employee exit before serving the pre-agreed period in the organization?	31 dated 02-07-2024	View	97(2)(e)
30	ERNST AND YOUNG LLP	Karnataka	1.Whether the professional services for assistance in filing of corporate tax returns provided to BWSSB is an exempt supply as referred in Sl No.3 (chapter 99) of table mentioned in Notification 12/2017 Central Tax (Rate) dated 28 June 2017?	30 dated 02-07-2024	View	97(2)(e)
29	GRASIM INDUSTRIES LIMITED	Karnataka		29 dated 25-06-2024	View
28	KANCHU SHIVA KUMAR	Karnataka		28 dated 25-06-2024	View
27	KANCHU SHIVA KUMAR	Karnataka		27 dated 25-06-2024	View
26	VINAY RAVEENDRA BABALESHWAR	Karnataka		26 dated 25-06-2024	View
25	PAN OFFICE SYSTEMS PRIVATE LIMITED	Karnataka	a. Should ARN/RFD-11 LUT copy accompany the Invoice? b. Can the ARN number of RFD-11 LUT be affixed on the invoice by sticker or should it be printed or can it be written by pen? c. If ARN/RFD-11 number is written/stickered on the invoice, should any additional document accompany the same?	25 dated 25-06-2024	View
24	T S TRANSPORT	Karnataka		24 dated 25-06-2024	View	98(2)
23	SAVITA PANDURANG RADDI	Karnataka	a.    What is the classification of service provided in accordance with Notification No.11/2017-CT (Rate) dated 28.06.2017 read with annexure attached to it, by the State of Karnataka to us for which royalty is being paid? b. Whether the said service can be classified under the 9973 specifically under 997337 as Licensing services for the right to mining including its exploration and evaluation or as any other service? c. Whether service provided by state Government of Karnataka is governed by the applicability of Notification No 13/2017-CT (Rate) dated 28.06.2017 under entry number 5 and whether we are taxable person in this case to discharge GST under reverse charge mechanism or whether given service is covered by exclusion clause number (1) of entry 5 and state Government of Karnataka is liable to discharge GST on same d.Whether royalty paid in respect of mining lease can be classified under “Licensing for the right to use minerals including its exploration falling under the Heading 9973 attracting GST at the same rate of tax as applicable on supply of like goods involving transfer in goods?	23 dated 25-06-2024	View
22	PADINJAREKUZHIVELIL KURIAKOSE RAJU	Karnataka	Rate of GST applicable to marine engine, fitter to fishing vessel, in the light of the circular No.52/26/2018-GST dated 09.08.2018	22 dated 25-06-2024	View
21	STUDIO 30 ARCHITECTS AND PLANNERS	Karnataka	Whether the provisions of section 12(3) of the IGST Act 2017 are applicable to a sub-consultant?	21 dated 25-06-2024	View
20	DEV AGROTOOLS PVT LTD	Karnataka	a.    Whether “Wooden handle” is exempted from GST which is manufactured by handi craft industries from Chanapattana, Karnataka?	20 dated 25-06-2024	View
19	FORTUNE AGRO INPEX	Karnataka		19 dated 25-06-2024	View
18	CONCEPT COLOUR TECNIKS PRIVATE LIMITED	Karnataka	a.    CGST and SGST rates as on powder coating for customers materials-use of phosphating chemicals and epoxy-polyester powder for aesthetic purpose. b. CGST and SGST rate as on phosphating for customers materials- use of phosphating chemicals for corrosion prevention.	18 dated 25-06-2024	View
17	KMS COACH BUILDER PRIVATE LIMITED	Karnataka		17 dated 25-06-2024	View
16	NALINA SONNEGOWDA	Karnataka		16 dated 25-06-2024	View
15	Turbotech Precision Engineering Pvt Ltd	Karnataka	a) What is the classification of goods and/or service for the supply of “EDF Thrusters with Battery Pack for Jet Suit” made by the applicant to the DEBEL? b) What is the applicable HSN code on such supplies of “EDF Thrusters with Battery Pack for Jet Suit” made by the applicant to the DEBEL? c) What is the applicable rate of tax under the Central Goods and Services Tax Act, 2017 and Karnataka State Goods and Services Tax Act, 2017 on the such supplies of “EDF Thrusters with Battery Pack for Jet Suit” made by the applicant to the DEBEL?	15 dated 21-05-2024	View	97(2)(e), 97(2)(a)
14	Technocrats Equipment sales and service	Karnataka	a) HSN code for Honey bee feeds b) Rate of Tax, if applicable c) Other details if any for specific product.	14 dated 21-05-2024	View	97(2)(e), 97(2)(a)
13	Karnataka Co-operative Milk Producers Federation	Karnataka	a)  Whether services provided by individual truck owners for transport of raw materials & finished goods including loading and unloading are liable for GST.	13 dated 21-05-2024	View	97(2)(e)
12	CRYSTAL INFOSYSTEMS AND SERVICES	Karnataka	a.  Whether the contract (excluding works contract service or other composite supplies involving supply of any goods) we are providing as ‘supply of Teachers and Lecturers to BBMP schools and colleges on outsourcing basis’ are exempted from both CGST and SGST? b. Can we raise the bills to BBMP without CGST and SGST? c. Shall we claim the payment for our services received from BBMP towards ‘supply of Teachers and Lecturers to BBMP schools and colleges on outsourcing basis’ as EXEMPTED SUPPLIES in our regular GST filing and ‘CRYSTAL INFOSYSTEMS AND SERVICES GSTIN 29ABCPV2897BZB’ is not liable to pay CGST and SGST to the Government of India? d. In order to ascertain taxability under GST for supply of teachers/Lecturers to the schools of BBMP on outsourced basis?	12 dated 15-04-2024	View	97(2)(b)
11	V CHITTI BABU	Karnataka	a.Admissibility of input tax credit of tax paid or deemed to have been paid on construction materials used in the construction of Marriage & Convention hall, output service of which is exigible to tax under the GST Act 2017. b.Admissibility of input tax credit of tax paid on inward supplies of D.G.Sets, Air Conditioners, Furnitures, Chairs etc., used in the course of business of letting out of Marriage/Convention halls.	11 dated 15-04-2024	View	98(4)
10	Elsevier BV	Karnataka	a)Whether the supply of services (subscription of Clinical Key) to the All India Institute of Medical Sciences (“AIIMS”) is exempt from GST under Entry No. 69 (b) (v) of the Notification No. 9/2017-IT (Rate) dated 28 June 2017? b)If the answer to the above question is negative, whether the Applicant or AIIMS needs to discharge the GST liability (i) for the period up to 30 September 2023 and (ii) for the period after 01 October 2023? c)Whether the supply of services (subscription of Clinical Key) to other educational institutions is exempt from GST under Entry No. 69 (b) (v) of the Notification No. 9/2017-IT (Rate) dated 28 June 2017?	10 dated 15-04-2024	View	97(2)(b)
09	SRI SRINIVASA CONSTRUCTIONS INDIA PVT. LTD	Karnataka	a.  Whether the applicant is required to add the work sites as additional place of business in their GST registration certificate? b. If the work site is required to be registered as additional place of business of the contractor then what is the address proof which will be required to be submitted by the applicant? Will the tender document/agreement entered into with Government/Government Authority will suffice as address proof for the purpose of processing the amendment application? c. If the work site is not required to be registered as additional place of business of the contractor then is it permissible for the contractor to procure the goods from his vendors (located within the state of Karnataka or outside) wherein the goods are directly delivered to the such work site? What are the documents that will be required to be carried along with such movement of goods? d. There are instances where the Contractor is required to move the goods from one location of the work site to another location of the work site, especially in case of road construction / drinking water supply work contracts. What are the documents which are required to be accompanied along with movement of goods?	09 dated 28-02-2024	View	98(2)
08	CHANGEJAR TECHNOLOGIES PVT. LTD.	Karnataka	a. Whether applicant, who only collects a commission as a percentage of the value of digital gold sold through its platform and the entire sale proceeds are paid directly to seller of Digital gold through an Escrow account would qualify him as an ‘Agent’ for the purpose of GST law and is therefore not covered by applicability of Notification No. 52/2018 – Central Tax, read with Section 52 of Central Goods and Services Tax, 2017 and corresponding state Notification 20/2018 (Karnataka) read with Section 52 of Karnataka Goods and Services Tax, 2017? b. Whether applicant is required to obtain registration as an E-commerce operator as per provisions of Rule 12 of Central Goods and Services Tax Rules, 2017?	08 dated 28-02-2024	View	97(2)(b)(f)
07	VISTAR AEC CONSULTANTS LLP	Karnataka	i.      Applicability of GST rate for revenue sharing scenarios between the joint bidders / partners on the project which partners have secured together Where: a. Partners have bid jointly and secured the project together b. Partners have entered into an agreement with the client together c. Partners have been given a work order by client ii. Can we consider the GST at the rate as applicable to the client? iii. Is the exemption of GST applicable to all partners as mentioned by TCC?	07 dated 29-01-2024	View	97(2)(e )
06	SPANDANA REHABILITATION RESEARCH AND TRAINING CENTRE PRIVATE LIMITED	Karnataka	i. Whether the supply of medicines, drugs and consumables used in the course of providing health care services to in-patients during the course of diagnosis and treatment during the patients admission in hospital would be considered as “Composite Supply” qualifying for exemption under the category of “health care services” as per Services Exempt Notification No. 12/2017-Central Tax (Rate) dated: 28-06-2017 read with Section 8(a) of the CGST Act, 2017 / KGST Act, 2017? ii. Whether the supply of food to in-patients would be considered as “Composite Supply” of health care services under CGST Act, 2017 & KGST Act, 2017 and consequently, can exemption under Services Exempt Notification No. 12/2017-Central Tax (Rate) dated: 28-06-2017 read with Section 8(a) of GST be claimed? iii. Retention Money: Whether GST is applicable on money retained by the applicant? iv. Whether GST is exempt on Fees collected from nurses and psychologists for imparting practical training?	06 dated 29-01-2024	View	97(2)(e )
05	SPANDANA PHARMA	Karnataka	i.    Whether the supply of medicines, drugs and consumables used in the course of providing health care services to in-patients during the course of diagnosis and treatment during the patients admission in hospital would be considered as “Composite Supply” qualifying for exemption under the category of “health care services” as per Services Exempt Notification No. 12/2017-Central Tax (Rate) dated: 28-06-2017 read with Section 8(a) of the CGST Act, 2017 / KGST Act, 2017? ii. Whether the supply of food to in-patients would be considered as “Composite Supply” of health care services under CGST Act, 2017 & KGST Act, 2017 and consequently, can exemption under Services Exempt Notification No. 12/2017-Central Tax (Rate) dated: 28-06-2017 read with Section 8(a) of GST be claimed? iii. Retention Money: Whether GST is applicable on money retained by the applicant? iv. Whether GST is exempt on Fees collected from nurses and psychologists for imparting practical training?	05 dated 29-01-2024	View	97(2)(e )
04	PARIWAR HOUSING CORPORATION	Karnataka	1. Whether the value as on JDA agreement date agreement should be considered or the value as on date of transfer to be considered for the purpose of discharging the GST on landowners portion?	04 dated 29-01-2024	View	98(2)
03	MANISH MANPOWER AGENCY	Karnataka	1. Whether the supply of manpower services to Zilla Panchayat (Social Welfare Department) and Taluka Panchayat are exempted from GST under Sl.No.3 of the Notification No.12/2017-Central Tax (Rate) as Pure Services?	03 dated 29-01-2024	View	97(2)( e)
02	GLOBAL MARKETING	Karnataka	a) Whether the tree pruners covered by HSN Code 82016000 relates to Agricultural implements manually operated or animal driven i.e. hand tools, such as spades, shovels, mattocks, picks, hoes, forks and rakes, axes, bill hooks and similar hewing tools; secateurs and “pruners of any kind”; scythes, sickles, hay knives, hedge shears, timber wedges and other tools of a kind used in agriculture, horticulture or forestry other than Ghamella”. b) Whether the supply of Agriculture Hand Tools i.e., Tree Pruners to farmer is exempt from the CGST /SGST/IGST Act.	02 dated 29-01-2024	View	97(2)( e)
01	AGP CITY GAS PRIVATE LIMITED	Karnataka	1) Whether statutory levies collected by the Petroleum & Explosives Safety Organization (PESO), Ministry of Commerce & Industry, GOI under the Explosives Act, 1884 read with the Gas Cylinder Rules, 2016 and Static & Mobile Pressure Vessels (Unfired) Rules, 2016 for issuance of licence are liable to goods and services tax as per the Central Goods and Services Tax Act, 2017 and rules framed thereunder? 2) If the answer to the above question is in the negative, whether statutory levies collected by the Petroleum & Explosives Safety Organization (PESO), Ministry of Commerce & Industry, GOI under the Explosives Act, 1884 read with the Gas Cylinder Rules, 2016 and Static & Mobile Pressure Vessels (Unfired) Rules, 2016 for issuance of licence are exempt under Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017 Sl-47 and also Notification No.9/2017-Integrated Tax (Rate) dated 28.6.2017 Sl-49? 3)Whether statutory levies collected by the Department of Factories, Boilers, Industrial Safety and Health, Government of Karnataka in respect of storage of LNG in the factory under the Factories Act, 1948 and Karnataka Factories Rules, 1969 for issuance of licence are liable to goods and services tax as per the Central Goods and Services Tax Act, 2017 and rules framed thereunder? 4) If the answer to the above question is in the negative, whether statutory levies collected by the Department of Factories, Boilers, Industrial Safety and Health, Government of Karnataka in respect of storage of LNG in the factory under the Factories Act, 1948 and Karnataka Factories Rules, 1969 for issuance of licence are exempt under Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017 Sl-47 and also Notification No.9/2017-Integrated Tax (Rate) dated 28.6.2017 Sl-49? 5) Whether statutory levies collected by the Karnataka Fire & Emergency Services Department, Government of Karnataka for issuance of a no objection certificate for a building plan approval are liable to goods and services tax as per the Central Goods and Services Tax Act, 2017 and rules framed thereunder? 6) If the answer to the above question is in the negative, whether statutory levies collected by the Karnataka Fire & Emergency Services Department, Government of Karnataka for issuance of a no objection certificate for a building plan approval are exempt under Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017 Sl-47 and also Notification No.9/2017-Integrated Tax (Rate) dated 28.6.2017 Sl-49? 7) Whether Registration fee or Stamp Duty collected by the Government of Karnataka in respect of registration of lease agreements for periods exceeding 11 months under Registration Act, 1908 are liable to goods and services tax as per the Central Goods and Services Tax Act, 2017 and rules framed thereunder? 8) If the answer to the above question is in the negative, whether Registration fee or Stamp Duty collected by the Government of Karnataka in respect of registration of agreements under Registration Act, 1908 are exempt under Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017 Sl-47 and also Notification No.9/2017-Integrated Tax (Rate) dated 28.6.2017 Sl-49? 9) Whether in the facts and circumstances of this applicant’s case obtaining of all the above licenses, permissions, sanctions, no-objections issued by the Central Government / Union Territory or local authority, qualify as a supply of service in terms of section 7 of the GSTA?	01 dated 29-01-2024	View	98(2)