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2019 (10) TMI 1135 - AUTHORITY FOR ADVANCE RULING, KARNATAKAClassification of services - composite supply or mixed supply - gamut of services collectively referred to as ‘Relocation Management Service’ provided by the Applicant - HELD THAT:- The agreement show that the applicant is only acting as an agent of the Company to which it is providing service and the service is based on the requirement of each of the employee of the Company. The employee of the Company chooses the services required for him and the applicant facilitates the provision of such services and each of the value of the services is fixed by the agreement and separate Service Charges are fixed. Hence there is no common price involved in the entire service and hence is not covered under a single package. Composite supply or not - HELD THAT:- The terms of the contract between the applicant and the Company are verified and found that the actual supply of relocation services is between the third parties to the Company and the invoicing is also done to the Companies by the third parties. The actual liability of paying the consideration is also on the Company and hence the Company is the recipient of service. The supplier of service is the Third Party Service Provider and each of these services may be provided by different Service providers. Hence this cannot be a composite supply, less so in the hands of the applicant - The billing is done as per the Schedule and includes Direct Cost of such service plus Service Fees plus taxes applicable. Each service has a separate service fees and the services are separately classifiable and if such services are billed in a common invoice that does not amount to a naturally bundled supply and hence the same is not a composite supply. Mixed supply or not - HELD THAT:- The transaction of the applicant is verified and in case where the third parties supplies individual services to the company where invoicing is done to the company directly, the same does not come under services supplied by the applicant in relation to such supply. But where the services are actually supplied by the applicant as “authorised services” by himself to the company, and in case where such multiple services are for a single price, then since such supplies would not constitute a composite supply, the same may be categorized as a “mixed supply”. The services supplied by the applicant do not constitute a Composite Supply and would be a mixed supply, when the services are billed for a single price in case where the relocation related services are actually provided by them - The services provided to the company as an agent are “management support services of relocation related services” which is a single service covered under SAC 9985 and is covered under entry 23(ii) of Notification No.11/2017-Central Tax (Rate) dated. 28.06.2017.
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