Goods transport agency exemption under GST requires a consignment note; mixed logistics and customs services do not qualify.

The GST exemption for services supplied by a goods transport agency to an unregistered person applies only where the supplier provides transport of goods by road as a notified GTA service, including issuance of a consignment note. On the facts, the applicant did not establish issuance of a consignment note and instead supplied separately billed customs clearance, loading and unloading, port handling, liner fee, transportation and destination services. The mixed bundle was therefore not shown to be GTA service within the exemption entry, and GST exemption was denied on the stated services.

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Issues: Whether the exemption for services provided by a goods transport agency to an unregistered person under the relevant GST exemption notifications applied to the applicant's services.

Analysis: The exemption applied only where the supplier was a goods transport agency and the service was in relation to transport of goods by road with issuance of a consignment note. The applicant did not establish issuance of a consignment note and, on the facts, supplied multiple separately billed services including customs clearance, loading and unloading, port handling, liner fee, transportation and destination services. The activity was therefore not shown to be the notified GTA service covered by the exemption entry.

Conclusion: The exemption was not applicable and the applicant was not entitled to GST exemption on the stated services.

Ratio Decidendi: An exemption entry for services supplied by a goods transport agency to an unregistered person is available only when the service answers the statutory definition of a goods transport agency service, including the issuance of a consignment note; a mixed bundle of separately charged logistics and customs-related services does not qualify merely because transportation forms part of the overall arrangement.

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