Bundled transport services with packing and loading qualify as composite GTA services under Entry 9(iii) notification 11/2017-CT(R)

AAR Telangana ruled on classification of bundled services including transportation, packing, loading, unloading, and unpacking. The authority held that such services constitute a composite supply falling under goods transport agency (GTA) services per Entry 9(iii) of notification 11/2017-CT(R), provided all services have direct and immediate link with the transport agreement for the same goods. The ruling emphasized that if contracts are substantially for transport with ancillary services, they qualify as GTA services rather than separate supplies.

---

---

Issues Involved:
The judgment involves determining whether the activities of a Goods Transport Agency (GTA) fall under the definition of a GTA as per the relevant provisions of the GST Act.

Brief Facts of the Case:
M/s. DRS Dilip Roadlines Limited, a GTA, has raised queries regarding whether their bundled services, including transportation, packing, loading, unloading, and unpacking, qualify as services provided by a GTA. They have cited relevant notifications, circulars, and previous rulings to support their case.

Questions Raised:
The primary question raised is whether the activities of M/s. DRS Dilip Roadlines Limited fall under the definition of a Goods Transport Agency.

Personal Hearing:
A personal hearing was conducted where the applicant reiterated their position that their activities constitute services provided by a GTA.

Discussion & Findings:
The Authority analyzed the definition of a composite supply as per the CGST Act and relevant case law. It was established that for services to be considered a composite supply, they must be naturally bundled and supplied together. The judgment also referenced specific notifications and Supreme Court rulings to clarify the scope of services provided by a GTA.

Ruling:
The Authority ruled that the activities of M/s. DRS Dilip Roadlines Limited would fall under the category of Goods Transport Agency if the services of transport, packing, unpacking, loading, and unloading are in relation to the same goods. However, if these services are in relation to different goods, they would not qualify as services provided by a GTA.

---