Voucher classification under GST determines supply treatment, time of supply, and tariff-based tax rates for closed prepaid instruments.

Own closed prepaid payment instruments accepted as consideration for future purchases were treated as vouchers, not actionable claims, because they identified the supplier and did not represent debt or beneficial interest in property; their issue in the course of business therefore constituted supply of goods. For vouchers, time of supply arose on the date of issue where the underlying goods were identifiable at that stage, and on the date of redemption where they were not. Classification also determined the GST rate: paper vouchers fell under the printed matter heading, while plastic gift cards fell under the relevant card heading, attracting the applicable tariff-based rates.

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Issues: (i) Whether own closed prepaid payment instruments issued to customers are vouchers and supply of goods under the GST law; (ii) when the time of supply arises for such vouchers; (iii) the applicable tax rate for paper vouchers and plastic gift cards classified under the relevant tariff headings.

Issue (i): Whether own closed prepaid payment instruments issued to customers are vouchers and supply of goods under the GST law.

Analysis: The instruments were accepted as consideration or part consideration for future purchases, identified the supplier, and were not claims to debt or beneficial interest in property. They therefore did not qualify as actionable claims. They satisfied the statutory definition of voucher and, being movable property other than money, fell within the definition of goods. Their issue for consideration in the course of business constituted supply.

Conclusion: Yes. The own closed PPIs are vouchers and amount to supply of goods.

Issue (ii): When the time of supply arises for such vouchers.

Analysis: For vouchers, the statutory rule fixes time of supply at the date of issue where the underlying supply is identifiable at that stage, and otherwise at the date of redemption. Since some vouchers were redeemable against specific identified goods while others were redeemable against any jewellery, the timing depended on that distinction.

Conclusion: The time of supply is the date of issue where the goods are identifiable, and the date of redemption in all other cases.

Issue (iii): The applicable tax rate for paper vouchers and plastic gift cards classified under the relevant tariff headings.

Analysis: Paper vouchers were treated as printed matter under the relevant tariff heading and plastic gift cards as cards under the other relevant heading. The notification prescribed different GST rates for those classifications.

Conclusion: Paper vouchers attract 6% CGST and 6% SGST, while gift cards attract 9% CGST and 9% SGST.

Final Conclusion: The ruling accepted the taxability of the applicant's own closed PPIs as vouchers treated as goods, fixed the time of supply according to identifiability of the underlying supply, and applied the tariff-based GST rates accordingly; the remaining questions were not answered for want of jurisdiction.

Ratio Decidendi: An instrument accepted as consideration for future supply, identifying the supplier and not representing a debt or beneficial interest, is a voucher and not an actionable claim; for vouchers, the time of supply follows the statutory issue-or-redemption rule, and classification determines the applicable GST rate.

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