Welfare support without consideration falls outside GST supply, and reverse charge does not apply to survivor assistance payments.

Women-survivor support funded through donations and interest income did not constitute a taxable supply under GST because no consideration was charged for the legal aid, medical assistance or vocational training provided. The applicant was not the recipient of the underlying services; the actual beneficiaries were the survivor women receiving the support. On that basis, the arrangement fell outside section 7(1) of the GST Act, and GST could not be fastened on the applicant under the reverse charge mechanism for reimbursements and financial assistance linked to the welfare activities.

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Issues: Whether the applicant's activities for women survivors of violence amounted to a supply of services under the GST law and whether the applicant was liable to GST, including under the reverse charge mechanism, on financial assistance and reimbursements made for legal, medical and training-related support.

Analysis: The applicant's assistance was directed to the survivor women, who were the actual recipients of the legal aid, medical assistance and vocational support. The applicant did not receive the services as a recipient; instead, it provided reimbursement and financial support to the survivors from donations and interest income. The activities were undertaken without charging any consideration for the facilitation of such support. In the absence of consideration, the activities did not satisfy the statutory definition of supply under section 7(1) of the GST Act. Since the applicant was also not the recipient of the underlying services, liability could not be fastened on it under the reverse charge mechanism for the payments made as support to the survivors.

Conclusion: The activities did not amount to supply of services, and the applicant was not liable to pay GST on the activities described or on the financial assistance extended to the survivors.

Final Conclusion: The ruling grants GST relief to the applicant by holding that its welfare assistance to survivors falls outside the taxable supply net.

Ratio Decidendi: A welfare support arrangement does not constitute a taxable supply where no consideration is charged and the payer is not the recipient of the underlying services.

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