Separate GST treatment for eco-tourism supplies applies where accommodation, food, guide services and accessories are invoiced independently.

Separate invoiced components of an eco-tourism package are taxed independently under GST according to the nature of each supply. Accommodation is assessed by reference to the declared tariff of the unit of accommodation, not on a per-head basis. Food and beverages billed separately attract the applicable restaurant rate. Authorized guide services are treated as a distinct taxable service, and trekking accessories are taxed as separate goods or services, as applicable. Where goods and services are separately shown and valued, the transaction is not treated as a single composite package for GST purposes; each supply bears tax at its own applicable rate.

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Issues: Whether, in respect of eco-tourism activities billed through separate invoices, accommodation, food and beverages, authorized guide services and trekking accessories are to be taxed independently under GST according to the rate applicable to each supply.

Analysis: The ruling proceeded on the basis that taxability must be determined from the actual nature of each supply. Accommodation was examined with reference to the declared tariff of the unit of accommodation, not on a per-head charge basis. Food and beverages supplied separately were considered taxable at the applicable restaurant rate. Guide services were treated as a distinct taxable service. The ruling also relied on the principle that where goods and services are separately shown and valued, each is liable to tax at the rate applicable to that supply.

Conclusion: Separate supplies disclosed through separate invoices are taxable independently at the rates applicable to accommodation, food and beverages, guide services and other goods or services, as the case may be.

Final Conclusion: The advance ruling accepted separate GST treatment for each independently invoiced component of the eco-tourism activity and rejected any single composite tax treatment for the package as a whole.

Ratio Decidendi: When distinct goods or services are separately supplied and separately valued, GST applies to each supply according to its own applicable rate rather than by treating the transaction as one undivided package.

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