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of Supply or not - club membership services - The amendment to Section 7 (mentioned above) clearly treats the applicant and its member as two different persons where there is a supply of services from the applicant to its members and thus as per the applicant's own submission that two different persons have been envisaged in the law to tax a transaction as a supply made for a consideration, it is found that in the instant case there is a supply by the applicant to its members and consideration is received in the form of “fees”. - AAR
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