2018 (11) TMI 959 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – 2018 (19) G. S. T. L. 173 (A. A. R. – GST) – Supply of Services – supply of “Business Support Service' comprising of 'Back Office Support' and “Accounting' which is its Principle Supply – intermediary services – Composite supply – zero rated supply – section 16 of IGST Act – export of services – supplier of service located in India – establishment of Distinct person – POPOS Rules.
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Held that:- Admittedly appellant is to provide back office support services, payroll processing, to maintain records of employee to overseas companies i.e. clients and after finalization of purchase / sale between the client and its customer. As per the legal understanding of the applicant aforesaid services proposed to be rendered qualify as 'Zero rated supply' in term of section 16 of the IGST Act. In order to have seal of approval on the issue, the present application is made and applicant has requested this authority to decide the issu
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f the jurisdictional officer with regards to condition at (v) of the said definition as to distinct person which would require more specific and detailed examination and verification on their part to get correct factual position in this regard, the services proposed to be rendered by the applicant do not qualify as 'export of services' as defined u/s.2(6) and thus not a 'zero rated supply' as per sec.16(I) of the IGST Act, 2017.
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The facts of the present case are different and not similar to facts of M/S GODADDY INDIA WEB SERVICES PVT. LTD. VERSUS COMMISSIONER OF SERVICE TAX, DELHI-IV [2016 (3) TMI 355 – AUTHORITY FOR ADVANCE RULINGS] – In case of GoDaddy the provision of support services was admittedly on principal to principal basis and were provided with sole intention of promoting the brand GoDaddy US in India for augmenting its business – In the present case, the activities undertaken by the applicant are for and on behalf of clients to facilitate supply of goods and services
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Service Tax Act, 2017 or not. At the outset, we would like to make it clear that the provisions of both the CGST Act and the GST Act are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST Act / MGST Act would be mentioned as being under the "GST Act' 02. FACTS AND CONTENTION – AS PER THE APPLICANT The submission (Brief facts of the case), as reproduced verbatim, could be seen thus – FACTS OF THE CASE 1. The Applicant M/S. Vservglobal Private Limited (hereinafter referred to as 'Vserv'), is an Indian Company having its office at Mumbai. The company is incorporated to provide back office support services to overseas companies (hereinafter referred to as 'Clients'). Clien
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& customer m) Follow up for smooth SOB (Shipping on Board) with supplier and forwarder n) log it in Excel Order Sheet – ETD -ETA (Estimated Date of Arrival -Estimated date of Departure) o) Get draft BL (Bill of Lading) prior to sailing p) follow up for full shipping documents with supplier q) Raise payment request in VOSS for supplier for balance or final payment r) Send payment request to Group Company for supplier for balance or final payment. s) Arrange inspection certificates if applicable t) Raise payment request for freight and inspection charges as applicable u) Arrange to send originals to Hong Kong v) Follow up for Originals sent to Customer from Group Company w) Notify ETA – reminder to Customer (ETA -Estimated time of arrival) x) troubleshooting 2. Apart from above, Vserv will also maintain records of employees of Clients, their payroll processing etc. All the payments to third parties like, supplier, Inspection Agency, Shipping Line, employees etc. will be done directly
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– (1) "zero rated supply" means any of the following supplies of goods or services or both, namely: a) export of goods or services or both; or b) supply of goods or services or both to a Special Economic Zone developer or a Special Economic Zone unit. 2. Subject to the provisions of sub-section (5) of section 17 of the Central Goods and Services Tax Act, credit of input tax may be availed for making zero-rated supplies, notwithstanding that such supply may be an exempt supply. 3. A registered person making zero rated supply shall be eligible to claim refund under either of the following options, namely: a) He may supply goods or services or both under bond or Letter of Undertaking, subject to such safeguards and procedure as may be prescribed, without payment of integrated tax and claim refund of unutilised input tax credit; or (b) he may supply goods or services or both, subject to such conditions, safeguards and procedure as may be prescribed, on payment of integrated tax
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reinafter. 7. supplier of Service is located in India. – The phrase 'location of Supplier of Service is defined in Section 2(71) of the Central Goods and Service Tax Act, 2017 which reads as under: "(71) "Location of the supplier of services" means – (a) where a supply is made from a place of business for which the registration has been obtained, location of such place of business, (b) where a supply is made from a place other than the place of business for which registration has been obtained (a fixed establishment elsewhere), the location of such fixed establishment; (c) Where a supply is made from more than one establishment, whether the place of business or fixed establishment, the location of the establishment most directly concerned with the provisions of the supply; and (d) In absence of such places, the location of the usual place of residence of the supplier;" 7 (a). In the instant case, the applicant is supplier of Services, which is a corporate entity
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e of business fixed establishment, the location of the establishment most directly concerned with the receipt the supply; and (d) in absence of such places, the location of the usual place of residence of the recipient;" 8 (a). The applicant is providing services to the overseas offices of recipient of services and such services are used by recipients for their business conducted by such overseas offices. The said overseas offices of recipients are covered under the definition of fixed establishment as contained in section 2(50) of the central Goods & services tax act, 2017, and therefore, the said second condition is also fulfilled. The definition of fixed establishment is reproduced here for ready reference. (50) fixed establishment means a place (other than the registered place of business) which is characterized by a sufficient degree of permanence and suitable structure in terms of human and technical resources to supply services, or to receive and use services for its ow
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Accounting and bookkeeping services 998223 Payroll services 998224 Other similar services n. e. c 9 (a). Vserv will be providing Accounting services, payroll services and similar other services. In view of applicant, services supplied /to be supplied by applicant are covered under Group 99822 covering Accounting services. The Accounting services are not covered under any sub-section from sub-section (3) to (13) of IGST Act, 2017 and hence, default provisions contained in section 13(2) of the IGST Act, 2017 is applicable and place of supply would be the location of recipient of services which would be outside India. 10. payment in convertible Foreign Exchange – As stated above, the payment for services will be received in Convertible Foreign Exchange, Thus, the said condition is also satisfied. 11. supplier & recipient not establishment of distinct person – the last condition is that the supplier of service and the recipient of service are not merely establishments of a distinct per
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ered by the applicant satisfy all the condition of "Export of Services" and therefore, covered under the definition of "Zero Rated Supply" Further Submissions made on 02.07.2018- 1, That, applicant M/S Vservglobal Private Limited, is highly obliged to the Hon'ble Authority for patient Personal Hearing on 26th June 2018 and allowing to file Written Submissions within a weeks' time. During Personal hearing a question was posed as to how the services rendered / proposed to be rendered by applicant is not covered under the definition of 'lntermediary Services' as defined under Section 1 3) of the Integrated Goods & Service Tax, 2017. The said definition is reproduced below for ready reference: (13) "Infermediary" means a broker, an agent or any other person, by whatever name called, who arranges or facilitates the supply of goods or services or both, or securities, between two or more persons, but does not include a person who supplies such
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on to recipient consisting of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply; Illustration. – Where goods are packed and transported with insurance, the supply of goods, packing materials, transport and insurance is a composite supply and supply of goods is a principal supply: 8. Tax liability on composite and mixed supplies. – The tax liability on a composite or a mixed supply shall be determined in the following manner, namely:- (a) a composite supply comprising two or more supplies. one of which is a principal supply, shall be treated as supply of such principal supply; and (b) a mixed supply comprising two or more supplies shall be treated as a supply of that particular supply which attracts the highest rate of tax. 4. In the instant case, the applicant proposes to supply "Business Support Service
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he 'main' service) or a supply of goods, between two or more persons, but does not include a person who provides the main service or supplies the goods on his account; " 6. From the above, it is clear that the definition of 'intermediary' in GST Law is identical to its definition under Service Tax. The above definition also contain an identical exclusion clause. CBEC in the Educational Guide released by it had explained the concept of 'Intermediary' and its exclusion clause in para 5.9.6, which read as under "Similarly, persons such as call centers, who provide services to their clients by dealing with the Customers of the client on the client 's behalf, but actually provided these services on their own account', will not be categorized as intermediaries. 7. In the instant ease also, the applicant is providing services to its clients on its own account and therefore, cannot be categorized as intermediary. An identical issue to the case in hand
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g, branding, offline marketing, oversight of quality of third party customer care Center and payment processing, on principal to principal basis These services are proposed to be provided with the sole intention of promoting the brand GoDaddy US in India and thus augmenting its business in India. Therefore, these services proposed to be provided by the applicant, would support the business interests of GoDaddy US in India. 12. It has been submitted by the applicant that services to be provided by the applicant are not peculiar only in applicant's case but are provided by various Indian entities to their overseas customers in India as a single package. Further, supporting the business of GoDaddy US in India is the main service and processing payments and oversight of services of third party Call Centers are ancillary and incidental to the provision of main service, i.e., business support service. Further, applicant would provide said services as a package and the payment for the ent
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by the applicant from Indian Customers. Applicant is to only receive from GoDaddy US, a fee equal to the operating cost incurred by the applicant plus mark up of 13% on such costs It is noticed that applicant is to receive said fees from GoDaddy US, even in respect of Indian Customers, who directly remit service charges to GoDaddy US through International Credit Card wherein applicant is not in the picture. This fact further shows that the applicant is not providing any service to Indian Customs. In view of above we rule as under; 9 The law point involved in the instant case and GoDaddy (supra) case is identical. Rather, in GoDaddy, the applicant had proposed to render services in respect of Indian Customers of GoDaddy, USA, and in the instant case, the services proposed to be provided would not be limited to Indian buyers / sellers of clients and they may be stationed anywhere in the world. 10 As submitted during Personal Hearing, the Applicant have already started serving M/s. Vikud
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reme Court in Columbia Sportswear Co, vs. Director of Income Tax, 2012 (283) E.L.T- 321 (S.C.) (copy enclosed). The Authority, thus, held that the advance ruling of the Authority is binding in the case of one transaction only and the parties involved in respect of that transaction and for other parties, the ruling will be of persuasive nature. The Authority, however, has clarified that this is not to say that a principle of law laid down in a case will not be followed in future. This decision of the Authority in Cyril Eugene Pereira, In re. (Supra) has been taken note of by this Court in Union of India & Anr. v. Azadi Bachao Andolan Anr. [(2003) 263 ITR 706 at 742] to hold that the advance ruling of the Authority is binding on the applicant, in respect of the transaction in relation to which the ruling had been sought and, on the Commissioner, and the income-tax authorities subordinate to him and has persuasive value in respect of other parties. However, it has also been rightly he
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ised the question that The applicant Vserv request this Hon'ble Authority to decide as to whether the aforesaid services proposed to be rendered qualify as 'Zero Rated Supply' in terms of section 16 of the Integrated Goods & Service Tax Act, 2017 or not". In reply to this it is submitting as under: As per provision of u/s 97(2 ) the application is not maintainable, due to the question pertains to zero rated Supply", it means it relates to place of supply and question pertains to place of supply cannot sought before Hon. Advance Ruling Authority. Firstly we have to see the provision same has reproduced as under:- CGST Section 97 (1)-An applicant desirous of obtaining an advance ruling under this Chapter may make an application in such form and manner and accompanied by such fee as may be prescribed, stating the question on which the advance ruling is sought. CGST Section 97 (2)-The question, on which the advance ruling is sought under this Act, shall be in resp
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nt is not maintainable. In this regard, if Advance Ruling Authority has accepted the application and treated is maintainable then my alternative submission is as under. The dealer has stated that, he has exported the services, and claiming that, the said services are Zero rated supply u/ s 16 of IGST Act 2017. As per definition u/s 2 (23) of IGST Act 2017 Zero Rated Supply , means a supply of any goods or Services or both in terms of section 16 of IGST Act 2017. As per section 16 of IGST Act zero rated supply means any of the following supplies of goods or services or both, namely: – Export of goods or services or both; or Supply of goods or services or both to a Special Economic Zone developer or a special Economic Zone unit. Means any supply of goods or service which is exported outside of India or supplied to any SEZ developer or any SEZ unit will be treated as zero rated supply. We are here restricted up to export of services, to qualify zero rated supply Export of service is The m
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. 1201-02A, 12th Floor, the Centrium, 60 Wyndham street, and central Hong Kong, china. The said firm is located outside India. In this case main issue is the place of supply of service is outside India or inside India, and if it is inside India then, it id intra state or inter-state. Firstly we have to crystallize supply of service. Section 12 – Place of supply of services where location of supplier and recipient is in India. IGST section 12 (1) the provisions of this section shall apply to determine the place of supply of services where the location of supplier of services and the location of the recipient of services is in India. IGST section 12 (2) the place of supply of services, except the services specified in sub-sections (3) to (14). (a) made to a registered person shall be the location of such person; (b) made to any person other than a registered person shall be,- (i) the location of the recipient where the address on record exists; and (ii) the location of the supplier of se
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cipient. ii. In any other case – Location of the supplier. Location of the Recipient of Services – Section 2 (14) 1. Where a supply is receives at a of business for which the registration has been obtained, the location of such place of business. 2. Where a suppIy is received at a lace other than the lace of business for which registration has been obtained (a fixed establishment elsewhere). the location of such fixed establishment. 3. Where a supply is received at more than one establishment whether the lace of business or fixed establishment the location of the establishment most directly concerned with the receipt t of the supply. And 4. In absence of such places, the location of the usual place of residence of the recipient. Now we have to see how above provision is applied to this case. In the instant case M/S Vikudha Overseas Corporation Limited, having registered office at Unit No. 1201-02A, 12th Floor, The Centrum, 60 Wyndham Street, and Central Hong Kong, China. on website of
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up Company, sister concern, etc. M/S Vikudha India Trading Limited., having register office DEIANTAK PLAYA, 201, OPP. WAMAN CENTER NIAKVVANA ROAD, MAROL, ANDHERI EAST MUMBAI Mumbai City MH 400059 IN (AS per Website of ministery of Commerce), and the director of companies are Mr. Deapkumar Balkishan Adukia, and Seema Sanjau Enand Tee promoters M/S Vikudha Overseas Corporation Limited, is Vikash Balkishan Adukia, Group CEO and Mr. Deap Adukia, Group COO. Mr. Deap Balkishan Adukia is also Director of M/S Vikudha India trading Limited. From the above discussion it is clear that, the M/S Vikudha India Trading Limited, is operated through 201, Dhantak Plaza, Opp Waman Centre Makwana Road, Marol, Andheri (E), Mumbai, for M/S Vikudha Overseas Corporation Limited. The nature and scope of the works of services stated in agreement are provided by Vservglobal Pvt Ltd to M/S Vikhudha India Trading Limited, which is operated in India for M/S Vikhudha Overseas Corporation Limited. It means all servic
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Explanation 1 in section 8, is also not satisfied. Section 8 of IGST Act is reproduced for ready reference. IGST Section 8 (1) Subject to the provisions of section 10, supply of goods………………… (2) Subject to the provisions of section 12, supply or services where the location of the supplier and the place supply of services are in the same State or same Union territory as intra-state supply: provided that the intra-state supply of services shall not include supply of services to or by a special economic be zone developer or a special economic zone unit. Explanation 1.-For the purposes of this Act, where a person has,- An establishment in India and any other establishment outside India; An establishment in a state or union territory and any other establishment outside that state or union territory; or An establishment in a state or union territory and any other establishment being a business vertical registered within that state or union te
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Establishment located in different states and union territory – As per section 25(5) Registration will be required to be obtained for each establishment located in different state or union territory. 3. Multiple business verticals in same state or union territory – If the person is carrying out any business through its branch or agency or representational office in any territory, it will be considered as having establishment in that territory. From the above after carefully perusal of distinct person provision, M/S Vikudha Overseas corporation Limited, and M/S Vikhudha India Limited, and M/S Vservglobal Pvt Ltd, are not a distinct person, for this provision, thus there cannot be export of service to own branch outside India. Form the above aforesaid fact, and related provision under the statute, the above transaction is not qualify export of services, hence not qualified under "Zero rated supply", it is Supply of Services to be treated as Intra-state. If we see the nature and
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the Service recipient. Nobody was present from the side of the jurisdictional officer. The application was admitted and final hearing was held on 26.062018, Sh. Bharat Bhushan, Advocate along with Sh. Mukesh Bagri, Director appeared and made contentions as per their written submissions and ARA application specifically insisting that they were not covered in definition of intermediary. They also requested for time to make further submissions latest by 02.07.2018 which was granted. The jurisdictional officer, Sh. Sachin Jadhav, State Tax officer (C- 713), Nodal -7, Mumbai appeared and stated that they would be making submissions in due course. 05. OBSERVATIONS We have perused the records on file and gone through the facts of the case and the made by the applicant and the departmental authority. It is seen that: The applicant is registered person under GST ACT who is supplier of Services, which is a corporate entity incorporated in India and having its registered office in Mumbai. The ord
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s having necessary competence to provide the said services. As such the party A has agreed to hire the party B to provide the said services and the Party B agreed to render the same in accordance with the provision of this contract. 3. article-1 :-Object of contract:- This service agreement aims to establish terms and conditions under which the party B commits to provide for party A for the services of back office administrative and accounting support. The nature and details of services to be provided to the party A by the party B throughout this are specified in Article 2 of this contract. Article 2: Nature and scope of work: The Party B will coordinate with buyer, seller and Other necessary parties for execution of purchase and sale contracts entered into by the party A. The party B will also maintain accounting of all these transactions. Party A will provide access to its software "VOSS" to the Party B for rendering the agreed services. The major service activities to be u
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an hours involved in each transaction. The services performer will be invoiced by 7th day of the following month. This invoice thus issued shall be payable by the end of the month in which the invoice is issued. On the basis of this service agreement applicant submits that the services proposed to be rendered such as back office administrative and accounting support services, a Pay roll processing and maintenance of records of employees of the client satisfy all the elements of "export of services as defined under the GST Act and therefore qualify as zero rated supply as per section 16 of the IGST Act. This proposition of law is strongly opposed by the jurisdictional officer. The jurisdictional officer has collected information about M/S Vikudha Overseas Corporation Limited Hong Kong China (the client), sister concern, etc. M/S Vikudha India Trading Limited., having registered office at DHANTAK PLAZA, 201, OPP. WAMAN MAKWANA ROAD, MAROC, ANDHERI EAST Munn bai City MH 400059 IN (AS
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applicant made further submission dated 02.07.2018 which is already reproduced above. We carefully have considered rival submissions and also scrutinized in detail different clauses of service agreement, Invoices and the bank statement. Admittedly appellant is to provide back office support services, payroll processing, to maintain records of employee to overseas companies i.e. clients and after finalization of purchase / sale between the client and its customer. As per the legal understanding of the applicant aforesaid services proposed to be rendered qualify as 'Zero rated supply' in term of sec.16 of the IGST Act. In order to have seal of approval on the issue, the present application is made and applicant has requested this authority to decide the issue. In order to examine the issue at hand the provisions contained in sec.16 of the IGST Act are relevant, which are reproduced below for ready reference- Section 16 of the IGST Act: (1) "zero rated supply" means any
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x paid on goods or services or both supplied, in accordance with the provisions of section 54 of the Central Goods and Services Tax Act or the rules made thereunder. Further considering the nature of transaction covered by the application understanding of the definition export of services as defined in the IGST Act is must, we reproduce the definition here in below: Section 2(6) of the IGST Act: "export of services" means the supply of any service when,- (i) the supplier of service is located in India; (ii) the recipient of service is located outside India; (iii) the place of supply of service is outside India; (iv) the payment for such service has been received by the supplier of service in convertible foreign exchange and (v) the supplier of service and the recipient of service are not merely establishments of a distinct person in accordance with Explanation I in section 8; In the course of final hearing a reasonable doubt was raised by the members whether the applicant is
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9;export of services' one of the condition is that the place of supply shall be outside India. The important clauses Of the service agreements are as below: Applicant commits to client to provide for services of back office administrative and accounting support. Applicant will coordinate with buyers, sellers and other necessary parties for execution of purchase and sell contract entered into by the clients. Clients will provide access to its software 'VOSS' to the applicant for rendering agreed services. Get SDF (Sales Detail Form) & PDF (Purchase Detail Form) from concerned party Generate order no in VOSS Create PO (Purchase Order) & SC (Sales Contract) in VOSS Send SC (Sales Contract) & PI (Proforma Invoice) to customer & get Si (Shipping Instructions) as well Send PO (Purchase Order) to supplier & Seek PI (Proforma Invoice) & Share SI (Shipping Instructions) Liaise with supplier for Cargo Readiness Liaise with inspection authorities if pre-shipmen
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its itself carrying out services in accordance with the instructions of the client. Applicant commits not to disclose business dealing of client to any third party / parties Applicant and client commit not to represent each other before a third party as agent and principal of the other party and entered into any kind of binding agreements. Applicant shall receive remuneration per purchase per sale. A sum of all activities mentioned above indicate applicant as a person who arranges or facilitate supply of goods or services or both between the overseas client and customers of the overseas client, and therefore applicant is clearly covered and falls in the definition of an intermediary as defined under the IGST Act. As the applicant is held as Intermediary the provisions pertaining to place of supply in case of intermediary services as provided in 8 of section 13 are relevant. In the instant case and as per applicants own admission of fact that applicant is supplier of Services, which is
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of services' as defined u/s.2(6) and thus not a 'zero rated supply' as per sec.16(I) of the IGST Act, 2017. Applicant submits that his case is covered by exclusion clause in definition of intermediary and in support of the same has strongly relied upon decision of advance ruling authority New Delhi in case of GoDaddy India Web services Pvt Ltd reported as 2016(46) STR806(AAR) dated 04.03.2016 (in short GoDaddy). We have gone through the facts of the case and the ruling and we find that facts of the present case are different and not similar to facts of M/S. GoDaddy. In case of GoDaddy the provision of support services was admittedly on principal to principal basis and were provided with sole intention of promoting the brand GoDaddy US in India for augmenting its business. In the present case we find that the activities undertaken by the applicant are for and on behalf of clients to facilitate supply of goods and services between the clients their customers. In view of this
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