18% GST is payable on the transportation by the Gujarat State Road Transport Corporation (GSRTC) buses ruled Gujarat Authority of Advance Ruling (AAR).

According to the information, the Gujarat Authority of Advance Ruling (AAR) consisting of Atul Mehta and Arun Richard has said that 18% GST is payable on the transportation by the Gujarat State Road Transport Corporation (GSRTC) buses. More than 8,700 buses are operated by GSRTC which is engaged in daily travel of intra state but it is mainly engaged in interstate passenger transportation services.

With a courier agency M/s Ashapura, Trade and Transport Private Limited, GSRTC made up an agreement where it is said that, to provide space in its buses, on top of the bus as well as in the bus cabin, for transporting parcels for Ashapura. All the parcels are booked by Ashapura and transported by the GSRTC buses from one station to another station which comes on its bus route.

GST

All the parcels are booked by Ashapura and transported by the GSRTC buses from one station to another station which comes on its bus route.

It was not issuing any consignment notes, nor it was engaged in door-to-door delivery of the parcels which was booked by Ashapura. It is said that as per the agreement GSRTC has received a consideration for the transportation of parcels.

The key difference between other transport agencies and Ashapura courier agency is that the parcels are picked up by the representative of the courier agency from the door of the sender and later transported and delivered to the door of the addressee. But on the other hand GSRTC is not engaged in door-to-door transportation it merely transport goods in its buses from one destination to another destination which is being handed over by Ashapura.
Now the point is whether GST should be applicable on the parcels of Ashapura that are being transported by GSRTC. Anothere point is whether GSRTC is eligible to avail exemption in terms of Sr.No 18 of Notification No 12/2017-Central Tax (Rate) whereby GSRTC is transporting parcels of Ashapura.

Meanwhile, Gujarat Authority of Advance Ruling (AAR) observed that the parcels which was supplying by GSRTC is of space/cabin/shed to Ashapura which office falls under the category of infrastructural support services, which is a subset of Business Support Services that means GSRTC supplies business support services to the recipients.

AAR

Now the point is whether GST should be applicable on the parcels of Ashapura that are being transported by GSRTC.