Club member fees taxable as GST service supply, while input tax credit on banquet and catering costs was denied.

Membership subscription and admission fees collected by a club from its members were held taxable under GST as consideration for supply of services. The Authority rejected the mutuality-based objection and treated the club's provision of facilities and benefits to members as falling within the statutory definition of supply and business. Input tax credit on banquet and catering services used for members' meetings and events was denied because food and beverage credit is blocked unless the inward supply is used for outward taxable supply of the same category or as part of a taxable composite or mixed supply, which was not established on the facts.

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Issues: (i) whether membership subscription and admission fees collected by the club from its members are liable to GST as supply of services; (ii) whether input tax credit on banquet and catering services used for members' meetings and events is available.

Issue (i): whether membership subscription and admission fees collected by the club from its members are liable to GST as supply of services.

Analysis: The club's reliance on mutuality and on the earlier advance ruling in the Lions Club matter was not accepted. The earlier ruling had been overruled in appeal, and the appellate findings were treated as applicable to the present facts. The Authority held that the GST definition of supply is wide, that membership fees are consideration for services rendered to members, and that provision by a club or association of facilities or benefits to its members falls within business. On that basis, the collections were treated as consideration for supply of services.

Conclusion: The receipt of membership subscription and admission fees from members is liable to GST and is taxable as supply of services.

Issue (ii): whether input tax credit on banquet and catering services used for members' meetings and events is available.

Analysis: The Authority applied the blocked credit rule for food and beverages and outdoor catering. It noted that credit is available only if the inward supply is used for making outward taxable supply of the same category or as an element of a taxable composite or mixed supply. The applicant did not produce evidence to satisfy either condition, and the proviso to the blocking provision was held not to be met.

Conclusion: Input tax credit on banquet and catering services is not available.

Final Conclusion: The club's member collections were held taxable under GST, and the credit claim on banquet and catering expenses was rejected.

Ratio Decidendi: A club's collections from members constitute taxable consideration for supply of services where the GST definition of supply and business is satisfied, and input tax credit on food and catering is barred unless the statutory exceptions to the blocked-credit provision are specifically established.

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