Redeemable vouchers traded by a non-issuer were treated as goods, making their transfer taxable under GST.

Redeemable vouchers traded by a non-issuer were treated as goods for GST purposes because they carried transferable value and ownership and therefore amounted to movable property. They were not regarded as money, as they did not discharge an obligation in the appellant's hands, and they were not actionable claims because they did not satisfy the statutory elements of debt or beneficial interest in property not in the claimant's possession. On that basis, trading in the vouchers constituted a supply of goods under GST, while the time of supply provision applicable to an issuer did not apply. The appeal was rejected.

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Issues: Whether vouchers traded by the appellant are money, goods, or actionable claims, and whether their supply is liable to GST with the applicable time of supply and rate.

Analysis: Vouchers were held to be payment instruments regulated by RBI, but in the appellant's hands they did not discharge an obligation and therefore did not qualify as money. They were further found to have transferable value and ownership and, on that basis, to be movable property falling within the definition of goods. The plea that vouchers were actionable claims was rejected because they were neither claims to unsecured debt nor claims to beneficial interest in movable property not in the claimant's possession. The reliance on lottery-ticket and meal-voucher precedents was distinguished on facts and on the statutory context. Once treated as goods, their supply by the appellant constituted a supply of goods under the GST law, and since the appellant was not the issuer of the vouchers, the applicable time of supply was not under the provision governing issue by an issuer.

Conclusion: The vouchers were held to be taxable goods and not actionable claims, and the appellant's appeal was rejected.

Final Conclusion: The ruling affirming GST liability on trading of the vouchers, along with the corresponding tax treatment, was sustained.

Ratio Decidendi: A redeemable voucher traded by a non-issuer may be treated as goods when it has transferable value and ownership, but it is not an actionable claim unless it answers the statutory elements of debt or beneficial interest in property outside the claimant's possession.

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