GST on joint bid revenue sharing depends on contractual supply chain, not assumed client rate or blanket exemption.

GST treatment of a joint bid revenue-sharing arrangement could not be determined on assumed facts where the applicant LLP issued tax invoices to its partner and no direct contract with the client was shown. On the available agreements, the applicant was found to be supplying services to the partner, not to the client, so the GST rate applicable to the client could not be applied by analogy. The claimed exemption for all partners was also held inapplicable to the applicant on the facts provided. The ruling therefore turned on the contractual structure and the absence of supporting documents for the assumed revenue-sharing scenario.

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Issues: (i) Whether an advance ruling can be given on assumed revenue-sharing scenarios in the absence of relevant documents; (ii) whether the applicant, in the facts of the case, can apply the GST rate applicable to the client and claim exemption applicable to the client.

Issue (i): Whether an advance ruling can be given on assumed revenue-sharing scenarios in the absence of relevant documents.

Analysis: The application and the supporting agreements showed that the work contract was between the municipal corporation and the lead consultant, while the applicant's own agreement was only with the lead consultant. The applicant also raised invoices on the lead consultant. In that setting, the authority held that revenue-sharing questions based on hypothetical situations could not be answered without concrete supporting documents.

Conclusion: The issue was answered against the applicant. Advance ruling could not be given on assumed scenarios in the absence of relevant documents.

Issue (ii): Whether the applicant, in the facts of the case, can apply the GST rate applicable to the client and claim exemption applicable to the client.

Analysis: The agreements and invoices established that there was no privity of contract between the municipal corporation and the applicant, and that the applicant supplied services to the lead consultant. The tax treatment applicable to the municipal corporation therefore did not extend to the applicant's supply, and the claimed client-based exemption was not available to the applicant.

Conclusion: The issue was answered against the applicant. The applicant could not apply the GST rate applicable to the client, and the client's exemption was not available to the applicant.

Final Conclusion: The application was not entertained on hypothetical revenue-sharing assumptions, and the applicant's supply was held to be separately taxable rather than covered by the client's tax position.

Ratio Decidendi: An advance ruling cannot be issued on hypothetical arrangements lacking supporting documents, and where there is no privity of contract with the client, the supplier's tax liability is determined by its own taxable supply and not by the client's exemption status.

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