Medical conference services classified as professional training composite supply under GST with ITC allowed on supporting services

The AAR Gujarat ruled on GST classification for medical conference services. ISCCM's supply to delegates constituted a composite supply with professional training as the principal supply, not accommodation or ancillary services. Exhibition services to exhibitors were classified under trade show organization services. Sponsorship services fell under reverse charge mechanism, not brand promotion. ITC was allowed on hotel convention services, food/beverages, rent-a-cab services with seating capacity under 13 persons, and exhibition setup services as these were used for making taxable composite supplies to delegates.

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Issues Involved:
1. Nature of service and classification for services provided by ISCCM to delegates and exhibitors.
2. Nature of service and classification for brand promotion packages offered by ISCCM.
3. GST liability on sponsorship services.
4. Admissibility of Input Tax Credit (ITC) for ISCCM on various services.

Issue-wise Detailed Analysis:

1. Nature of Service and Classification:
- Service to Delegates: ISCCM provides a composite package to delegates, including technical seminars, exhibition access, accommodation, cultural programs, meals, and airport transfers. The principal supply is identified as professional service supply, classified under SAC 998399.
- Service to Exhibitors: ISCCM organizes trade fairs and exhibitions where exhibitors showcase their products/services. The participation fees are for organizing the exhibition, classified under SAC 998596 as 'events, exhibitions, conventions and trade shows organization and assistance services.'

2. Brand Promotion Packages:
- Nature and Classification: ISCCM offers brand promotion packages including branding on various materials and presentations. These services are classified under SAC 998397 as 'Sponsorship services and brand promotion services.'
- GST Liability: The GST liability for sponsorship services falls on the service recipient if the recipient is a body corporate or partnership firm located in the taxable territory, under the reverse charge mechanism as per Notification 13/2017-CT(R) dated 28-6-17. If the recipient is not a body corporate/firm, ISCCM must pay GST on a forward charge basis.

3. Admissibility of Input Tax Credit (ITC):
- Hotel Services: ITC is admissible on services provided by the hotel, including accommodation, food, and beverages, as these are used in the course of business and are part of a taxable composite supply.
- Food and Beverages by Outside Caterers: ITC on these services is admissible under Section 17(5)(b)(i) of the CGST Act, as they are used for making an outward taxable supply.
- Event Manager Services: ITC on services like pickup & drop, exhibition stall setup, and tenting is admissible as these are input services used in ISCCM's business.

Findings:
- ISCCM’s Supply to Delegates: The principal supply is professional service supply (SAC 998399).
- ISCCM’s Supply to Exhibitors: Classified under SAC 998596.
- Brand Promotion Packages: Classified under SAC 998397.
- GST Liability on Sponsorship Services: Falls on the recipient under reverse charge if the recipient is a body corporate or partnership firm; otherwise, ISCCM pays GST on forward charge.
- ITC Admissibility: ITC is admissible on hotel services, food and beverages by outside caterers, and event manager services.

Ruling:
1. ISCCM supplies a composite service to delegates with professional service as the principal supply (SAC 998399).
2. ISCCM provides 'Exhibition, Trade show organization, and assistance services' to exhibitors (SAC 998596).
3. ISCCM supplies sponsorship services (SAC 998397).
4. GST liability on sponsorship services is on the recipient if they are a body corporate or partnership firm; otherwise, ISCCM is liable.
5. ITC is admissible for ISCCM on the specified services.

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