TMI Blog2018 (6) TMI 1195X X X X Extracts X X X X X X X X Extracts X X X X ..... security etc. Mere renting of space cannot be said to be in the nature of service provided for storage or warehousing of goods. From the nature of service provided by the applicant, as described in the application, it is clear that the applicant only rent the storage premises. Once the storage premises is rented by the applicant to its customers, what use the customer makes of such premises doesn’t have any bearing on the nature of service provided by the applicant - the applicant is required to pay Goods and Services Tax at 18% (CGST 9% + GGST 9% or IGST 18%) for aforesaid activity carried out by them classifiable as ‘Rental or leasing services involving own or leased non-residential property’ (Service Accounting Code – 997212). Ruli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7 of the Central Goods and Services Tax Act, 2017 (herein after referred to as the CGST Act, 2017) defines the supply as all form of supply of goods or services or both such as sale, transfer, barter, exchange, license, rental, lease or disposal made or agreed to be made for a consideration by a person in course or furtherance of business and there shall be levied a tax called the CGST on all intra-state supplies of goods or services or both as per section 9 of the CGST Act, 2017 and IGST shall be levied on all inter-state supplies as per Section 5 of the Integrated Goods and Services Tax Act, 2017 (herein after referred to as the IGST Act, 2017). 2.2 It has been opined by the Commissionerate that the activity carried out by the war ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ehouse owner. Sample copies of invoices issued by the applicant have also been submitted. 3. We have considered the submissions made by the applicant in their application for advance ruling as well as submissions made at the time of personal hearing. We have also considered the opinion, information, documents and views submitted by the Goods Services Tax and Central Excise Commissionerate, Kutch (Gandhidham). 4. The applicant has requested for advance ruling on applicability of GST for invoices raised to their clients for storage charges for storing their imported agri product in godowns at Gandhidham. 5. On perusal of sample copies of invoices (Invoice No. RS/GR/17-18/027 dated 19.07.2017 and Invoice No. RS/GR/17-18/043 dated 29 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... service provided for storage or warehousing of goods. 6.4 The applicant has submitted in the application that as a part of their services, it provides service of warehouse / space on rent to their customers, where they (customers of applicant) store imported agricultural commodities. From the nature of service provided by the applicant, as described in the application, it is clear that the applicant only rent the storage premises. Once the storage premises is rented by the applicant to its customers, what use the customer makes of such premises doesn t have any bearing on the nature of service provided by the applicant. 6.5 In the sample copies of invoices (Invoice No. RS/GR/17-18/027 dated 19.07.2017 and Invoice No. RS/GR/17-18/043 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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