AAR held that the applicant's proposed activities constitute...

AAR held that the applicant's proposed activities constitute 'goods transport agency' (GTA) services because it will transport goods by road and issue consignment notes transferring lien and responsibility for safe delivery. Issuance of a consignment note was treated as a sine qua non for GTA status, consistent with the pre-GST service tax regime. The end customer, who pays the transport charges, is the 'recipient of service' under GST. Consequently, GTA services provided by the applicant to unregistered end customers through an electronic commerce operator's portal fall within Sl. No. 21A of Notification No. 12/2017-CT (Rate), as amended, and are exempt, including strictly incidental/ancillary services to such transport.