Issues: (i) Whether the Authority has jurisdiction to rule on a claim for refund of GST paid on the upfront lease amount; (ii) Whether input tax credit of GST paid or payable on the upfront amount for a long-term lease of industrial land, intended for construction of a factory, is admissible.

Issue (i): Whether the Authority has jurisdiction to rule on a claim for refund of GST paid on the upfront lease amount.

Analysis: The matters on which an advance ruling may be sought are exhaustively specified in Section 97(2). Refund of tax paid is not among those specified matters, whereas admissibility of input tax credit is expressly covered.

Conclusion: The Authority lacks jurisdiction to answer the refund query; the refund claim was rejected.

Issue (ii): Whether input tax credit of GST paid or payable on the upfront amount for a long-term lease of industrial land, intended for construction of a factory, is admissible.

Analysis: Input tax credit is blocked for goods or services received for construction of an immovable property on the recipient's own account, other than plant and machinery. Land, buildings and civil structures are expressly excluded from plant and machinery. The leased plot was intended for construction of a factory building; consequently, the upfront lease service was treated as pertaining to land acquired for construction of an immovable property.

Conclusion: Input tax credit of GST charged on the upfront lease amount is inadmissible, against the assessee.

Final Conclusion: The refund component could not be entertained in advance-ruling jurisdiction, and the tax paid on the upfront lease consideration remains blocked credit.

Ratio Decidendi: GST paid on a long-term lease of land obtained for constructing an immovable property on the recipient's own account is blocked input tax credit where the leased land and resulting civil construction do not qualify as plant and machinery.

Issues: Whether compensation recovered from transporters for loss, damage, shortage, delay, leakage, theft, contamination, or similar transit defaults amounts to a supply of services under para 5(e) of Schedule II read with Section 7 of the Central Goods and Services Tax Act, 2017.

Analysis: The compensation arises from breach or non-performance of the transport contract and is linked to loss suffered by the applicant, not to any independent promise by the applicant to refrain from, tolerate, or do any act for the transporters. The amounts are in the nature of liquidated damages or compensatory recoveries, intended to ensure performance and deter default. Such receipts do not represent consideration for a separate service and do not satisfy the essential requirement of supply under the GST law.

Conclusion: The compensation recovered from transporters is not a supply of services and is not taxable under para 5(e) of Schedule II read with Section 7 of the Central Goods and Services Tax Act, 2017.

Issues: (i) whether services under the National Mental Health Programme were exempt as charitable activities under Entry No. 1; (ii) whether self-defence training for women and training under the Suraksha Setu and education department programmes were exempt under Entry No. 72; (iii) whether training to goldsmiths under the Gujarat Matikaam Kalakari and Rural Technology Institute and PM Vishwakarma related training were exempt under Entry No. 72; (iv) whether vocational training at Kasturba Gandhi Balika Vidyalay was exempt under Entry No. 72; (v) whether seminars for development of women were exempt under Entries No. 71 or 72; (vi) whether yoga camps were exempt under Entry No. 1; and (vii) whether de-addiction seminars and training for cleaning and sanitation were exempt under Entry No. 1, and whether blood donation camps and road safety training were exempt.

Issue (i): whether services under the National Mental Health Programme were exempt as charitable activities under Entry No. 1.

Analysis: The applicant was registered under section 12AB of the Income-tax Act, 1961, and the work order related to mental health awareness, education and training activities for vulnerable persons. The definition of charitable activities in the notification includes public health awareness and advancement of educational programmes or skill development relating to physically or mentally abused and traumatized persons.

Conclusion: The services under the National Mental Health Programme were held exempt under Entry No. 1, subject to possession of valid section 12AB registration.

Issue (ii): whether self-defence training for women and training under the Suraksha Setu and education department programmes were exempt under Entry No. 72.

Analysis: The work orders were issued by police authorities and government educational offices, and the training was funded from government sources. The services were provided to government departments or government-run schools under training programmes where the expenditure was borne by the State Government.

Conclusion: The self-defence training services were held exempt under Entry No. 72.

Issue (iii): whether training to goldsmiths under the Gujarat Matikaam Kalakari and Rural Technology Institute and PM Vishwakarma related training were exempt under Entry No. 72.

Analysis: The training was found to be part of the PM Vishwakarma Scheme, a fully Central Government funded scheme, and the applicant had been designated to conduct artisan mobilization and basic training for the relevant trade beneficiaries.

Conclusion: The training to goldsmiths and related PM Vishwakarma training were held exempt under Entry No. 72.

Issue (iv): whether vocational training at Kasturba Gandhi Balika Vidyalay was exempt under Entry No. 72.

Analysis: The training was provided under work orders issued by the school authorities in a government-supported school scheme, and the expenditure was borne through government support.

Conclusion: The vocational training at Kasturba Gandhi Balika Vidyalay was held exempt under Entry No. 72.

Issue (v): whether seminars for development of women were exempt under Entries No. 71 or 72.

Analysis: The applicant was not registered as a project implementation agency under the relevant skill development scheme, and the factual record was insufficient to bring the activity within the claimed entries.

Conclusion: The claim for exemption for seminars for development of women was rejected.

Issue (vi): whether yoga camps were exempt under Entry No. 1.

Analysis: Yoga falls within the notified charitable activity of advancement of religion, spirituality or yoga, and the applicant satisfied the charitable registration requirement, subject to valid section 12AB registration.

Conclusion: The yoga camp services were held exempt under Entry No. 1, subject to possession of valid section 12AB registration.

Issue (vii): whether de-addiction seminars and training for cleaning and sanitation were exempt under Entry No. 1, and whether blood donation camps and road safety training were exempt.

Analysis: De-addiction seminars and cleaning and sanitation training were treated as public awareness of preventive health and therefore within charitable activities. Blood donation camps were held to be primarily for collection and supply of blood, with only ancillary screening measures, and road safety training was held not to amount to preventive health for the purpose of the notification.

Conclusion: De-addiction seminars and cleaning and sanitation training were held exempt under Entry No. 1, while blood donation camps and road safety training were held not exempt.

Final Conclusion: The ruling granted exemption for the identified charitable and government-funded training activities, but denied exemption for the women development seminar, blood donation camps and road safety training, and declined to answer the alternative and unsupported questions.

Ratio Decidendi: Exemption under Notification No. 12/2017-Central Tax (Rate) depends on the activity falling squarely within the notified entry and, where required, on the applicant's valid charitable registration or proof that the service is supplied under a government-funded training programme.

Issues: (i) Whether statutory deposits towards Net Present Value, compensatory afforestation and allied CAMPA charges for forest clearance constitute consideration for a supply of service by Government; (ii) whether such deposits are exempt under Notification No. 12/2017-Central Tax (Rate); and (iii) whether GST is payable under forward charge or reverse charge.

Issue (i): Whether statutory deposits towards Net Present Value, compensatory afforestation and allied CAMPA charges for forest clearance constitute consideration for a supply of service by Government.

Analysis: Grant of permission to divert forest land for non-forest use was held to be an activity undertaken by Government in furtherance of the applicant's business. The mandatory deposits were found to be directly linked to the grant of approval and were not voluntary payments. The amounts paid into the CAMPA fund were therefore treated as consideration within the meaning of section 2(31), and the grant of permission was treated as a supply of service within section 7.

Conclusion: Yes. The deposits constitute consideration for a supply of service by Government.

Issue (ii): Whether such deposits are exempt under Notification No. 12/2017-Central Tax (Rate).

Analysis: The exemption entries relied upon were confined to services in relation to functions entrusted to municipalities and panchayats under Articles 243W and 243G. Permission for diversion of forest land under the Forest (Conservation) regime was held not to fall within those exempt categories.

Conclusion: No. The deposits are not exempt under the notification.

Issue (iii): Whether GST is payable under forward charge or reverse charge.

Analysis: Once the transaction was characterised as a taxable supply of service by Government to a business entity, the conditions of Notification No. 13/2017-Central Tax (Rate) were held to be satisfied. The applicant, being a business entity receiving services from Government, was held liable to discharge tax under reverse charge.

Conclusion: GST is payable by the applicant under reverse charge mechanism.

Final Conclusion: The application was decided against the applicant on all substantive questions, with the CAMPA-related statutory deposits held taxable as consideration for a Government service and liable to GST under reverse charge.

Ratio Decidendi: A mandatory statutory payment made as a condition for obtaining governmental approval to use forest land for non-forest purposes constitutes consideration for a taxable service when the approval confers a legally enforceable business benefit, and the recipient business entity is liable to GST under the reverse charge notification applicable to Government services.

Issues: (i) Whether the applicant qualifies as a Governmental Authority; (ii) Whether the services rendered in relation to the smart city and ESCO project are exempt under the relevant notification entry; (iii) Whether the applicant acts as a pure agent for remittance of the contractor's share, so as to exclude such from the taxable value.

Issue (i): Whether the applicant qualifies as a Governmental Authority.

Analysis: The definition in the exemption notification requires an authority or body established by Government with ninety per cent or more participation by way of equity or control to carry out a function entrusted to a Municipality or Panchayat. The applicant was found not to be set up by an Act, but to have been established by the Government of Uttarakhand as a special purpose vehicle under the smart cities framework. Its equity was held entirely through Government bodies, satisfying the equity/control requirement.

Conclusion: The applicant qualifies as a Governmental Authority.

Issue (ii): Whether the services rendered in relation to the smart city and ESCO project are exempt under the relevant notification entry.

Analysis: The notification grants exemption to services by a Governmental Authority by way of any activity in relation to functions entrusted to a Municipality under Article 243W of the Constitution. Water supply and allied urban infrastructure functions fall within the Twelfth Schedule. The applicant's services in relation to the project were found to be connected with municipal water supply functions and thus within the scope of the exemption entry.

Conclusion: The services are exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate), as amended.

Issue (iii): Whether the applicant acts as a pure agent for remittance of the contractor's share, so as to exclude such amount from the taxable value.

Analysis: Rule 33 permits exclusion only where the supplier acts as a pure agent on authorisation, the payment is separately indicated, and the procurements are in addition to the supplier's own services. On the facts, the applicant was held to be an active participant in execution, supervision and financial management of the project, and not a mere conduit for the contractor's payment.

Conclusion: The applicant does not qualify as a pure agent, and the remitted amounts are not excludible from the value of supply.

Final Conclusion: The ruling recognises the applicant as a Governmental Authority and grants exemption for its municipal-function related services, but denies pure-agent treatment for the contractor-linked remittances.

Ratio Decidendi: An entity established by Government with the requisite equity or control to perform municipal functions qualifies as a Governmental Authority, services by such authority in relation to Article 243W functions are exempt, and pure-agent exclusion under Rule 33 is unavailable unless all statutory conditions are strictly satisfied.

Issues: Whether the applicant's questions relating to refund of accumulated input tax credit under the inverted duty structure, including GST paid on mining royalty under reverse charge, were admissible within the advance ruling jurisdiction and whether the application was barred because the refund claim had already been decided in proceedings under the GST law.

Analysis: The application, though framed with reference to input tax credit, in substance sought a ruling on refund entitlement and refund computation under Section 54(3) of the Central Goods and Services Tax Act, 2017 read with Rule 89(5) of the Central Goods and Services Tax Rules, 2017. Such questions did not fall within the matters enumerated in Section 97(2) of the Central Goods and Services Tax Act, 2017, since the expression "admissibility of input tax credit" does not extend to adjudication on refund of accumulated credit. The Authority further noted that the refund claim had already been rejected by the jurisdictional authority, attracting the bar under Section 98(2) of the Central Goods and Services Tax Act, 2017 against admitting an application on a question already decided in proceedings under the Act.

Conclusion: The application was not maintainable before the Authority and was rejected at the admission stage.

Issues: (i) Whether the retrospective insertion of sub-section (5) in section 16 of the GST Act entitled the applicant to reclaim input tax credit earlier reversed for invoices pertaining to January to March 2020; (ii) Whether such reclaim of reversed input tax credit amounted to a refund barred by section 150 of the Finance (No. 2) Act, 2024.

Issue (i): Whether the retrospective insertion of sub-section (5) in section 16 of the GST Act entitled the applicant to reclaim input tax credit earlier reversed for invoices pertaining to January to March 2020.

Analysis: Section 16(5) was inserted to override the time restriction in section 16(4) for specified financial years, but it did not dispense with the substantive conditions in section 16(2). The applicant had already availed credit in the relevant returns within the time then permitted, and the earlier reversal was made because the supplier's compliance had not satisfied the governing conditions as then understood. The amendment did not create a fresh entitlement to restore credit that had already been reversed on the facts of the case.

Conclusion: The applicant is not entitled to reclaim the reversed input tax credit on the strength of section 16(5).

Issue (ii): Whether such reclaim of reversed input tax credit amounted to a refund barred by section 150 of the Finance (No. 2) Act, 2024.

Analysis: The reclaim of credit reversed pursuant to the earlier ruling was treated as the practical equivalent of a refund of input tax credit. The expression used in section 150 was read broadly so that a narrow construction confined to section 54 of the GST Act would render the reference to reversed credit ineffective and lead to an unreasonable result. The statutory bar therefore applied.

Conclusion: The reclaim of the reversed input tax credit is hit by section 150 and is not permissible.

Final Conclusion: The retrospective amendment did not revive the applicant's reversed credit, and the requested re-availment remains impermissible under the statutory bar on refund of reversed input tax credit.

Ratio Decidendi: A retrospective extension of the time limit for availing input tax credit does not, by itself, revive credit already reversed where the substantive conditions for entitlement remain unfulfilled, and re-availment of such reversed credit is treated as a barred refund when the statute expressly excludes refund of input tax credit reversed.

Issues: (i) Whether psyllium seeds supplied in their natural, raw and unprocessed form, without drying, freezing, crushing or other processing, qualify as "fresh" psyllium seeds and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025. (ii) Whether the same goods qualify as "goods of seed quality" and are exempt under Entry 77 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Issue (i): Whether psyllium seeds supplied in their natural, raw and unprocessed form, without drying, freezing, crushing or other processing, qualify as "fresh" psyllium seeds and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Analysis: Psyllium seeds were found classifiable under heading 1211 of the Customs Tariff Act, 1975. The supply described by the applicant consisted of seeds procured from farmers through APMC auctions in the same condition as harvested, with no artificial drying, freezing or other processing. Applying the tariff description, the HSN notes, and the GST clarification on the distinction between fresh and dried goods, the Authority treated the goods as fresh agricultural produce in common parlance. Entry 87 of Notification No. 10/2025-Central Tax (Rate) specifically covers plants and parts of plants, including seeds and fruits, of the relevant kind when fresh or chilled.

Conclusion: Yes. The psyllium seeds, as supplied, are fresh and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Issue (ii): Whether the same goods qualify as "goods of seed quality" and are exempt under Entry 77 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Analysis: Entry 77 is a general exemption for all goods of seed quality under Chapter 12, whereas Entry 87 is a specific exemption covering heading 1211. Since psyllium seeds were held to fall squarely within the specific heading-based entry and to be fresh goods, the Authority treated the general seed-quality entry as not requiring separate acceptance for the ruling sought.

Conclusion: No. The claim under Entry 77 was not accepted in view of the finding under Issue (i).

Final Conclusion: The supply of psyllium seeds in the stated unprocessed condition is exempt as fresh goods under the specific heading-based exemption, and no separate exemption was granted on the alternative seed-quality basis.

Ratio Decidendi: Where goods are specifically covered by a heading-based exemption for fresh plant parts, the specific entry governs and the fresh character of the supply is determined by the absence of drying, freezing, or similar processing.

Outcome: The application for advance ruling was rejected as the questions raised were already pending in proceedings initiated by the jurisdictional authority.

Issues: Whether the PP packing box manufactured by the applicant is classifiable under tariff item 39231090, and whether the lids, caps and covers supplied with such boxes fall under tariff item 39235090 for GST purposes.

Analysis: The goods were examined with reference to Chapter 39 of the Customs Tariff Act, 1975, which covers plastics and articles thereof. On the basis of the product description, manufacturing process, invoices and images produced, the Authority found that the PP packing box is an article for packing of goods made of plastic and is appropriately covered by heading 3923. Within that heading, the box-shaped containers fall under sub-heading 392310, and since they do not answer the more specific residual tariff items within that sub-heading, they are classifiable under tariff item 39231090. The stoppers, lids, caps and other closures associated with the boxes fall under sub-heading 392350 and, not being bottle caps or other specified items, are classifiable under tariff item 39235090. The corresponding GST rate entry was also noticed in Schedule II of Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017.

Conclusion: The PP packing box manufactured by the applicant is classifiable under tariff item 39231090, and the lids, caps and covers of the boxes are classifiable under tariff item 39235090.

Issues: Whether laundry soap bars weighing less than 500 grams are classifiable as toilet soap for the purpose of the concessional GST rate under Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025.

Analysis: The relevant notification placed toilet soap in bars, cakes, moulded pieces or shapes under the concessional entry and covered soap other than toilet soap under the residuary higher-rate entry. The classification had to be determined by the tariff scheme and the nature of the goods. The Authority compared toilet soap and laundry soap on the basis of common parlance, use, composition and the BIS specifications relied upon by the applicant. It found that toilet soap is meant for personal and bathing use, while laundry soap is designed for washing fabrics, and that the two products differ in chemical composition and commercial identity. The Customs Tariff also separately identifies laundry soaps under tariff item 34011942, distinct from toilet soaps under tariff item 340111.

Conclusion: Laundry soap is not included in toilet soap and does not qualify for the concessional 5% rate. Laundry soap bars weighing less than 500 grams fall under tariff item 34011942 and attract tax at 9% CGST plus 9% SGST under the higher-rate entry.

Issues: (i) Whether input tax credit of GST charged by the canteen service provider is admissible on catering services provided to regular employees where the canteen is maintained under a statutory obligation; (ii) whether such input tax credit is admissible on canteen services attributable to contract workers; (iii) whether credit is available on the entire value charged by the canteen service provider or only to the extent of the cost actually borne by the applicant.

Issue (i): Whether input tax credit of GST charged by the canteen service provider is admissible on catering services provided to regular employees where the canteen is maintained under a statutory obligation.

Analysis: The proviso to Section 17(5)(b) of the Central Goods and Services Tax Act, 2017 removes the blockage on credit where the inward supply is obligatory for an employer to provide under any law. The canteen facility was held to be a statutory requirement under Section 46 of the Factories Act, 1948, and the recovery from employees was treated as incidental and subsidised. The cited circular and rate notification were also relied upon in support of admissibility.

Conclusion: Input tax credit is admissible in respect of canteen services provided to regular employees, but only to the extent of the cost actually borne by the applicant.

Issue (ii): Whether such input tax credit is admissible on canteen services attributable to contract workers.

Analysis: The applicant was found to have no direct employer-employee relationship with contract workers, and no statutory obligation under the Factories Act, 1948 to provide canteen facilities to them. The exception in the proviso to Section 17(5)(b) of the Central Goods and Services Tax Act, 2017 therefore did not apply, and the inward supply was not treated as one used for making an outward taxable supply of the same category.

Conclusion: Input tax credit on canteen services attributable to contract workers is not admissible.

Issue (iii): Whether input tax credit is available on the entire value charged by the canteen service provider or only to the extent of the cost actually borne by the applicant.

Analysis: The ruling applied the statutory-obligation exception only to the extent of actual expenditure incurred by the applicant in discharging that obligation. Amounts recovered from employees were treated as not borne by the applicant, so credit on that recovered portion was disallowed.

Conclusion: Input tax credit is restricted to the portion of canteen cost actually borne by the applicant, and is not available on the recovered portion.

Final Conclusion: The ruling grants credit for statutory canteen services for regular employees only to the extent of the applicant's own cost and denies credit for services attributable to contract workers, leaving the relief partly in favour of the applicant.

Ratio Decidendi: Credit on blocked food and catering services is available only where a statutory obligation exists, and then only to the extent the registered person actually bears the cost of the inward supply.

Issues: Whether the three questions seeking a ruling on the documentary sufficiency for proving supplies for authorized operations and the need for invoice endorsement in DTA-to-SEZ and intra-SEZ transactions fell within the scope of advance ruling under section 97 of the CGST Act, 2017.

Analysis: The questions were confined to whether LOA, eligibility certificates, and other documents were sufficient, or whether endorsement by the Specified Officer was mandatory. Such questions did not concern classification, applicability of a notification, time or value of supply, input tax credit, liability to pay tax, registration, or whether an activity amounted to a supply. They were therefore outside the statutory matters on which an advance ruling could be sought.

Conclusion: The questions were held to be outside the ambit of section 97 of the CGST Act, 2017, and no ruling was given on the merits.

Final Conclusion: The application was not entertained on jurisdictional grounds, leaving the substantive GST and SEZ documentary issues unanswered.

Ratio Decidendi: An advance ruling can be given only on matters expressly covered by section 97(2) of the CGST Act, 2017, and a request confined to documentary sufficiency or procedural endorsement requirements is not maintainable where it does not fall within those categories.

Issues: Whether AAC bricks/blocks are classifiable under Heading 6904 as ceramic building bricks, or under Heading 6810 as articles of cement, concrete or artificial stone.

Analysis: The classification was examined by comparing the declared composition and manufacturing process of the goods with the competing tariff entries and Chapter Note 1 to Chapter 69. The goods were found to undergo autoclaving and not the kind of firing required for ceramic products under Chapter 69. The chemical analysis relied upon by the applicant was also held not to establish that the product satisfied the criteria of a ceramic brick. The tariff description and explanatory notes for Heading 6810 were found to align with the goods, and the claim that Heading 6904 should prevail was rejected.

Conclusion: AAC bricks/blocks are not classifiable under Heading 6904 and are correctly classifiable under Heading 6810; the ruling is against the applicant.

Issues: Whether input tax credit is admissible on inputs and input services used for construction of a concrete VCV tower erected to support and operate the VCV lines for manufacture of EHV cables, in view of the restrictions under section 17(5)(c) and 17(5)(d) of the CGST Act.

Analysis: The concrete tower was found to be an essential and integral structural support for the vertical continuous vulcanization line, with the machinery fixed to earth by foundation and structural support. On the facts placed, the tower was not treated as a mere civil structure housing equipment, but as part of the foundation and structural support of plant and machinery used for making outward supplies. Since the explanation to section 17 includes foundation and structural supports within plant and machinery, the exclusion in clauses (c) and (d) was held not to apply. The ruling also drew support from the departmental clarification on ducts and manholes used in OFC networks, applying the same principle that credit is not blocked where the structure forms part of plant and machinery.

Conclusion: Input tax credit on inputs and input services used for construction of the concrete VCV tower is admissible and is not blocked under section 17(5)(c) or 17(5)(d) of the CGST Act.

Ratio Decidendi: Where a concrete structure is established as foundation or structural support for plant and machinery used in making outward supplies, it falls within the statutory definition of plant and machinery and credit on its construction is not blocked under section 17(5)(c) and 17(5)(d).

Issues: Whether input tax credit is available on inputs and input services used for setting up the continuous catenary vulcanization tower used for manufacture of insulated cables, and whether such credit is barred under the blocked credit provisions relating to construction of immovable property other than plant and machinery.

Analysis: The ruling turned on the statutory exclusion for works contract services and other goods or services used for construction of immovable property, except where the construction is of plant and machinery. The expression "plant and machinery" was applied to mean apparatus, equipment and machinery fixed to earth by foundation or structural support, including such foundation and structural supports, but excluding land, building, other civil structures, telecommunication towers and pipelines laid outside the factory premises. On the facts, the tower was found to be a specialised steel structure essential to support and erect the CCV line, with its height, layout and load-bearing function being integral to the manufacturing process. The tower was therefore treated as structural support for the machinery and not as a disqualifying civil structure. The clarification issued on ducts and manholes used in optical fibre cable networks was also relied upon by analogy to support the conclusion that such support structures are not hit by the restriction when they form part of plant and machinery.

Conclusion: Input tax credit on inputs and input services used for construction of the CCV tower is admissible and is not blocked under the cited provisions.

Issues: Whether rose water supplied as "Pooja Panneer" exclusively for puja or ritual use is classifiable under the exempt category of puja samagri, or under tariff heading 3301 9079 as an aqueous solution of essential oils liable to GST.

Analysis: The Authority held that the exemption entry for puja samagri under the relevant notification is exhaustive because the word "namely" confines the exemption to the specifically listed goods. Rose water is not among those listed items. The product was found to be made by mixing synthetic rose perfume with deionised or RO water, and therefore it is not an aqueous distillate of essential oils under heading 3301 9060. Since it is a preparation of water and essential oil solution, it falls under heading 3301 9079. The claimed puja use and retail labelling did not alter the tariff classification, and the product was not covered by the exemption for puja samagri.

Conclusion: The product is classifiable under HSN 3301 9079 and is taxable at 18% GST.

Issues: (i) Whether the amount collected by the temple for issuing a licence to collect human hair from the temple premises falls within the scope of supply under the GST law; (ii) whether the exemption for human hair extends to the auction or licence amount charged by the temple for permitting collection of the hair.

Issue (i): Whether the amount collected by the temple for issuing a licence to collect human hair from the temple premises falls within the scope of supply under the GST law.

Analysis: The activity undertaken by the temple was not merely an act connected with worship, but the grant of a licence to the successful bidder to enter the premises and collect tonsured hair. The Authority treated the transaction as a distinct commercial arrangement for consideration, and held that a licence is included within the statutory concept of supply when made for consideration in the course or furtherance of business. It further held that the temple was not itself supplying the hair, but was transferring a right to collect it through a taxable service falling under the relevant service classification.

Conclusion: Yes. The licence amount collected by the temple towards collection of human hair is a supply of service and falls within the scope of supply under the GST law.

Issue (ii): Whether the exemption for human hair extends to the auction or licence amount charged by the temple for permitting collection of the hair.

Analysis: The exemption relied upon was confined to the supply of human hair as goods. The Authority distinguished the present transaction as a service of granting a licence to collect hair from the temple premises, and not the exempt supply of the hair itself. It therefore held that the exemption notification for human hair did not cover the licence consideration charged by the temple.

Conclusion: No. The amount charged for the licence to collect human hair is not exempt and is taxable.

Final Conclusion: The ruling accepts that the temple's licence arrangement is a taxable supply of service, while denying exemption for the licence amount on the footing that the exemption applies only to human hair as goods.

Ratio Decidendi: A grant of licence for consideration to collect goods from temple premises is a taxable supply of service when it is a distinct commercial transaction, and an exemption applicable to the goods themselves does not extend to the consideration charged for the licence to collect them.

Issues: (i) Whether commission paid to a foreign director for marketing and sourcing of orders constituted import of services and attracted GST under reverse charge; (ii) whether commission paid to foreign marketing agents for sourcing orders constituted import of services and attracted GST under reverse charge; (iii) whether charges paid to foreign clearing and forwarding agents for services performed outside India constituted import of services and attracted GST under reverse charge.

Issue (i): Whether commission paid to a foreign director for marketing and sourcing of orders constituted import of services and attracted GST under reverse charge.

Analysis: The director was located outside India, the recipient was in India, and the place of supply was the recipient's location under Section 13(2) of the Integrated Goods and Services Tax Act, 2017. The commission was paid for services rendered to the applicant, and the supply satisfied the definition of import of services under Section 2(11) of the Integrated Goods and Services Tax Act, 2017. The notified reverse charge entry applied to services supplied from a non-taxable territory to a person in taxable territory.

Conclusion: GST is payable on the commission paid to the foreign director, and the tax is chargeable under reverse charge.

Issue (ii): Whether commission paid to foreign marketing agents for sourcing orders constituted import of services and attracted GST under reverse charge.

Analysis: The foreign marketing agents arranged or facilitated the supply of goods for commission and therefore answered the description of intermediary services under Section 2(13) of the Integrated Goods and Services Tax Act, 2017. For intermediary services, the place of supply is the location of the supplier under Section 13(8) of the Integrated Goods and Services Tax Act, 2017, so the place of supply was outside India. The statutory condition of import of services under Section 2(11) was therefore not met.

Conclusion: GST is not payable on the commission paid to the foreign marketing agents under reverse charge.

Issue (iii): Whether charges paid to foreign clearing and forwarding agents for services performed outside India constituted import of services and attracted GST under reverse charge.

Analysis: The clearing and forwarding agents were located in a non-taxable territory and supplied logistics-related services on their own account. The recipient was in India and the place of supply was in India for purposes of import of services, bringing the transaction within Section 2(11) of the Integrated Goods and Services Tax Act, 2017. The notified reverse charge mechanism applied to the services received from outside India.

Conclusion: GST is payable on the charges paid to the foreign clearing and forwarding agents, and the tax is chargeable under reverse charge.

Final Conclusion: The ruling holds that GST is chargeable on commission paid to the foreign director and on charges paid to foreign clearing and forwarding agents, while commission paid to foreign marketing agents is outside the reverse charge levy.

Ratio Decidendi: Services supplied by a person located outside India are taxable as import of services when the recipient is in India and the place of supply is in India, but intermediary services are excluded from import of services because their place of supply is the supplier's location.

Issues: (i) Whether the supply of Coursera User License to OSDA is classifiable under Heading 9992 as Education Service; (ii) whether exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) is available; (iii) whether the supply is more appropriately classifiable under Heading 9973, and if so under SAC 997331; (iv) whether the supply is classifiable under Heading 9984 as Online Content Services.

Issue (i): Whether the supply of Coursera User License to OSDA is classifiable under Heading 9992 as Education Service

Analysis: The supply consisted only of a user license conferring access to Coursera's proprietary digital platform. The Applicant did not itself impart education, training, coaching, or instruction, and the educational content was delivered through third-party universities and instructors on the platform. The essential character of the transaction was access to digital content, not the provision of education services.

Conclusion: The supply is not classifiable under Heading 9992. The answer is against the assessee.

Issue (ii): Whether exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) is available

Analysis: The exemption was contingent upon the supply being classifiable under Heading 9992 and being provided under a training programme to the specified Government recipient. Since the supply was not Education Service, and OSDA was an autonomous society rather than the State Government itself, the conditions for the exemption were not satisfied. Exemption notifications were required to be construed strictly.

Conclusion: The exemption under Sl. No. 72 is not available. The answer is against the assessee.

Issue (iii): Whether the supply is more appropriately classifiable under Heading 9973, and if so under SAC 997331

Analysis: The transaction was treated as a principal-to-principal licensing arrangement in which the Applicant distributed Coursera's products and raised invoices on OSDA on its own account. The dominant element was the grant of a non-exclusive right to access a proprietary platform. In classification, the more specific description was preferred over a broader residual heading. On that basis, the supply fell within Heading 9973, and SAC 997331 was treated as the appropriate entry.

Conclusion: The supply is classifiable under Heading 9973, specifically SAC 997331. The answer is in favour of the Revenue.

Issue (iv): Whether the supply is classifiable under Heading 9984 as Online Content Services

Analysis: Although online content services could broadly describe the use of the platform, that heading was residual compared with the more specific licensing entry under Heading 9973. The tax rate was the same under either classification, but the proper classification remained the licensing category.

Conclusion: The supply is not to be classified under Heading 9984 in preference to Heading 9973. The answer is against the assessee.

Final Conclusion: The ruling holds that the Coursera user-license supply to OSDA is a taxable licensing service under Heading 9973, with no exemption under Sl. No. 72, and not an education service or preferred online content service.

Ratio Decidendi: For GST classification, the specific nature of the supply governs, and a transaction that merely grants a non-exclusive right to access proprietary digital content is classifiable as a licensing service rather than as education service or a residual online content service; exemption entries must also be construed strictly and only on fulfilment of all stated conditions.