TaxTMI 
TaxTMI 
2019 (1) TMI 1091
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....pport services" falling under HSN code 9985 or "Intermediary service" classifiable under HSN code 9961 / 9962? 3. Whether the services provided by the Applicant is an export of services as defined under Section 2(6) of the Integrated Goods and Services Tax Act 2017? At the outset, we would like to make it clear that the provisions of both the CGST Act and the MGST Act are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST Act / MGST Act would be mentioned as being under the "GST Act". FACTS AND CONTENTION - AS PER THE APPLICANT The submissions, as reproduced verbatim, could be seen thus- STATEMENT OF THE RELEVANT FACTS HAVING A BEARING ON THE QUESTIONS: Asahi Kasei India Private Limited (hereinafter referred to as the "Applicant") is a company incorporated in India in August 2012. The Applicant is a subsidiary of Asahi Kasei Corporation, Japan ("Asahi Japan"). Asahi Ja....
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....pplied by the Applicant under the Service Agreement dated 1 March 2013 constitute a supply of "Support services" falling under HSN code 9985 "Intermediary service" classifiable under HSN code 9961 /9962? Statement of facts having a bearing on the question The scope of the services provided by the Applicant under Service Agreement with Asahi Japan [dated 01 March 2013] as amended on 05 January 2017 are highlighted at Clauses 4 to 8 of the Agreement. The relevant extract of the agreement is reproduced hereunder: "4. Party B (i.e. the Applicant) agrees to conduct from time to time, as and when requested by Party A (being Asahi Japan), research on the matters related to the functions of the holding company, such as corporate accounting, corporate finance, corporate personnel and labour relations, corporate research and development, quality assurance and corporate intellectual property, and provide Party A with its report of the research thereon. 5. Party B agrees to provide Party A from time to time, as and when requested by Party A, with economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and o....
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....t to existing and perspective customers to understand their requirement, their business plan and their feedback and reporting to Asahi Japan (iii) Providing information on the products of Asahi Japan to the existing and perspective customers (iv) Generating marketing leads and relaying to Asahi Japan (v) Helping customer on the product trial (vi) Facilitating meeting between customers and agent Asahi Japan Statement containing the applicant's interpretation of law 1. There are two possible classifications for the services supplied by the Applicant. The relevant HSN codes along with its description are tabulated hereunder: SR.NO. HSN CODE TARIFF ENTRY i. 9961 / 9962 Intermediary service - Services in wholesale trade and Services in retail trade ii. 9985 Support Service 2. The term "intermediary" is defined under Section 2(13) of the Integrated Goods and Services Tax Act 2017 IGST Act"). The relevant extract of the said definition is set out hereunder: "(13) "intermediary" means a broker, an agent or any other person, by whatever name called, who arranges or facilitates the supply of goods or services or both,....
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....lik): - An agent employed to make bargains and contracts between other persons in the matters of trade, commerce and navigation, by explaining the intentions of both the parties and negotiating in such a manner as to put those who employ him in a condition to treat together personally; (2) and more commonly an agent employed by one party only to make a binding contract with another. b. Agent i. Shorter Oxford English Dictionary (Deluxe Edition): A person who acts for another un business, politics, etc.; ii. Section 182 of the Indian Contract Act 1872: - An "Agent" is a person employed to do any act for another or to represent another in dealings with third persons; iii. Concise Law Dictionary (2008 Edition): - An agent acts on behalf of his principal and often uses is name and his acts in that capacity are attributable to the principal; 5. Having understood the meaning of the terms '"broker" and an "agent", it would be imperative to examine the scope of the term ll any other person, by whatever name called". In this regard, it is humbly submitted that the scope of this phrase is restricted by the preceding words "broker or agent" by applying the principle of "Ejus....
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....y meaning of the terms "broker" and "agent" along with the aforementioned judicial precedents, it can be construed that the only persons appointed in representative capacities can be covered within the scope of the first limb of aforesaid definition (Intermediary). 10. As per the second part of the definition, an intermediary "Arranges or facilitates the supply of goods or services or both, or securities between two or more persons". It is further submitted that the service heading 9961 / 9962 refers to intermediary service in wholesale trade and retail trade. Wholesale trade and retail trade relates to the activity of selling of goods. 11, The Applicant submits that the dictionary meaning of facilitation is to make easy or easier, make something possible or aiding or helping. Thus, the dictionary meaning of facilitation is very wide and covers processing, storage, transport, advertising, sales promotion etc, all activities as each and every activity aids or smoothens supply of goods. Goods Transport service (9965), Transport support service (9967), advertising and market research service (9983) are separate service classification. If such a wide meaning is adopted, it will r....
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....f the definition of the term "intermediary". 16. Since the services have been provided by the Applicant as an independent contractor, the Applicant would automatically fall within the exclusion provided in the third limb of the definition. In view of the above, the applicant would not be construed as an intermediary in terms of Section 2(13) of the IGST Act. 17. The activity of sales promotion and marketing are not selling of goods and therefore, such activities would not be classifiable under the said heading. The activities of the Applicant are in relation to market survey, market intelligence and leads, sales promotion, liaising and customer relation. The Applicant never participates in the actual sales negotiation except as interpreter. 18. It is submitted that- a. Composite supply has been defined under Section 2(30) of the Central Goods and Services Tax Act 2017 ("CGST Act') as follows: "(30) "composite supply" means a supply made by a taxable person to a recipient con5isting of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary cour....
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....aries." In the instant case, although the Applicant deals with the service recipients customers, but the same is for the purpose of providing services to the service recipient on its own account. Consequently, the services provided by the Applicant cannot be classified as Intermediary services". 20. In an identical case as the present situation, GODADDY India Web Services Pvt. Ltd. had filed an Advance Ruling under the Service tax regime [2016 (46) STR 806 (A.A.R.)] = 2016 (3) TMI 355 - AUTHORITY FOR ADVANCE RULINGS. The relevant extract of the judgment is reproduced below: 11. Applicant proposes to provide support services in relation to marketing, branding, offline marketing, oversight of quality of third party customer care centre and payment processing, on principal to principal basis. These services are proposed to be provided with the sole intention of promoting the brand of GODaddy US. Therefore, these services provided by the applicant to GoDaddy cannot be categorized as intermediary or services, as intermediary services. 12. It has been submitted by the applicant that services to be provided by the applicant are not peculiar only in applicant's case but are pro....
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....- For the purposes of this clause, the expression infrastructural support services" includes providing office along with office utilities, lounge, reception with competent personnel to handle messages, secretaria services, internet and telecom facilities, pantry and security;" [Pre-negative List regime] "Section 65B(49) "support services means infrastructural, operational, administrative, logistic, marketing or any other support of any kind comprising functions that entities carry out in ordinary course of operations themselves but may obtain as services by outsourcing from others for any reason whatsoever and shall include advertisement and promotion, construction or works contract, renting of immovable property, security, testing and analysis;" [Negative List regime] 24. From the above, it can be construed that marketing services, advertisement and promotion services, customer relationship management, evaluation of prospective customers, etc. would qualify to be in the nature of support services. 25. In this regard, it is submitted that the scope of the services that is to be provided by the Applicant to the Asahi Kasei group are of similar nature. Thus, the supply....
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....pient and the same shall not be made available to employees or other personnel of service recipient who may visit India; h) Providing information on products and its functioning or similar such services to service recipient's customers and notifying service recipient of any consumer complaints; i) Monitoring regulatory developments (including, where possible, establishing and maintaining contact with regulatory agencies) and reporting the same to the service recipient; and j) Any other assistance in the context of the above, regarding service recipient's marketing activities that may be reasonably requested by service recipient after the effective date in writing to AKI." It may however be noted that the scope of service for the marketing services agreement with APNA do not include the points (c), (g) and (i) as mentioned above Statement containing the applicant's interpretation of law As in case of Question No. 2 above QUESTION NO. 3 Question on which advance ruling is required Whether the services provided by the Applicant is an export of services as defined under Section 2(6) of the Integrated Goods and Services Tax Act 2017? Statement of facts havi....
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....ient is located outside India. In order to determine the place of supply, we refer to Section 13 of the IGST Act which provides for the place of supply of services in case where either the service recipient or the service provider is situated outside India. The services provided by the Applicant is in the nature of "Support services" classifiable under HSN code 9985. The place of supply in the instant case would therefore be determined as per the general rule i.e. as per Section 13(2) of the IGST Act. The said sub-section provides that the location of the recipient of services shall be the place of supply of services. Applying the above to the present case, the place of supply of services shall be the location of the Asahi Kasei group i.e. outside India. d. Condition IV - Payment is received in convertible foreign exchange As mentioned in the foregoing paragraphs, the consideration charged by the Applicant is in convertible foreign exchange i.e. Japanese Yen / United States Dollar. e. Condition V - Supplier of service and recipient of service are not merely establishment of distinct person Explanation 1 to Section 8 inter alia provides that where a person has an esta....
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....01 March 2013) as amended on 05 January 2017 are highlighted at Clauses 4 to 8 of the Agreement. The relevant extract of the agreement is reproduced hereunder: "4. Party B (i.e. the Applicant) agrees to conduct from time to time, as and when requested by Party A (being Asahi Kasei Corporation, Japan), research on the matters related to the functions of the holding company, such as corporate accounting, corporate finance, corporate personnel and labor relations, corporate research and development, quality assurance and corporate intellectual property, and provide Party A with its report of the research thereon. 5. Party B agrees to provide Party A from time to time, as and when requested by Party A, with economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and outlook together with similar information concerning such other industries in the Territory (i.e. India or any other mutually agreed territory) as Party A may from time to time request. In the event Party A should require more detailed information than that so provided by Party B, Party B shall exert its best efforts to obtain such further or ....
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....ervices' under Heading No.998371; ii) Research on the matter of corporate intellectual property appears to come under 'Legal documentation and certification services concerning patents, copyrights and other intellectual property rights services' which fall under Heading No.998213 iii) The economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and outlook together with similar information concerning such other industries, appears to fall under 'Original compilations of facts or information' which fall under Heading No.998394' / Business Support Service(9985). iv) Providing necessary assistance in liasoning and coordinating activities for the representatives of Party A, would qualify to be in the nature of business support services' which fall under Heading No.99859. v) Regarding Para 8 of the agreement, it is felt that Advance Ruling cannot be given because without proper and full facts. In this Para, conditions like 'but not limited to' is mentioned, which does not give a clear picture of what services it pertains to. Hence, Advance Ruling for Para 8 cannot be given. vi) Regarding Para 9 of ....
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.... close commercial relationships between AM and customers; g) Providing staff of AM or its customers visiting the territory with such assistance as may be reasonably requested by AM, including but not limited to providing information, guide, escort and interpreting services during Customers visits; for the sake of clarity, the premises of AKI (applicant) will not be the premises of AM and the same shall not be made available to employees or other personnel of AM who may visit India; h) Providing information on products and its functioning or similar such services to AM's customers and notifying AM of any Customer complaints; i) Monitoring regulatory developments (including, where possible, establishing and maintaining contact with regulatory agencies) and reporting on these to AM; and j) Any other assistance in the context of the above, regarding AM's marketing activities that may be reasonably requested by AM after the Effective Date in writing to AKI(Applicant)." From perusal of the extract of the above agreement dated 01.12.2012 it is seen that the Applicant is engaged in the activities for AM(service recipient), Conducting market surveys and providing the AM with ....
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....advertising policy appears to fall under 'Advertising services' under Heading No.998361. iii) Assisting the AM in conducting sales prospection through participation in industry events such as scientific gatherings, exhibitions, trade shows and the like, appears to come under 'Events, exhibitions, conventions and trade shows organization and assistance services' falling under Heading No.998596. iv) Liaising with Customers and potential Customers and to collect their product development plans and strategy and "road-maps", as well as their product specifications, and reporting to AM abroad, information obtained through such interactions appears to be connected to the services at Para 10 above as principal supplies, therefore in terms of Section 8 of the Central Goods and Service Tax Act, 2017 read with Section 20 of the Integra ted Goods and Service Tax Act, 2017. Therefore the said service 'Original compilations of facts or information' which individually fall under Heading No.998394' / Business Support Service(9985) will be supplied as Composite Supply and in terms of Section of the IGST Act, 2017. v) Providing any feedback to AM that would help improve AM's marketing; Faci....
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....ient of service is located outside India; (iii) The place of supply of service is outside India; (iv) The payment for such service has been received by the supplier of service in covetable foreign exchange; and (v) The supplier of service and the recipient of service are not merely establishments of a distinct person in accordance with Explanation in Section 8;" "(13) "intermediary" means a broker, an agent or any other person, by whatever name called, who arranges or facilitates the supply of goods or services or both, or securities, between two or more persons, but does not include a person who supplies such goods or services or both or securities on his own account". The Applicant, M/s. Asahi Kasei India Pvt. Ltd. has submitted that they are fulfilling all the conditions Section 2(6) of IGST Act, discussed in detail hereunder: a. Condition I - Supplier of service is located in India. The applicant is registered under GST and providing the service from Maharashtra, India. Hence fulfilling the first condition with reference to term "location of the supplier of service" is located in India, as defined under Section 2(15) of the IGST Act.....
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....porate finance, corporate personnel and labor relations, corporate research and development, market surveys appears to come under the category of 'Market Research services' under Heading No.998371, will be covered under Section 13(2) of the IGST Act, 2017 and place of supply of service or shall be the location of the recipient of services; 2. Research on the matter of corporate intellectual property appears to come under 'Legal documentation and certification services concerning patents, copyrights and other intellectual property rights services' which fall under Heading No.998213', will be covered under Section 13(2) of the IGST Act,2017 and place of supply of service or shall be the location of the recipient of services; 3. The economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and outlook together with similar information concerning such other industries, appears to fall under Original compilations of facts or information' which fall under Heading No.998394' / Business Support Service(9985), will be covered under Section 13(2) of the IGST Act, 2017 and place of supply of service or shall be th....
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....of the IGST Act,2017 as 'intermediary services' and the place of supply of service shall be the location where the services are actually performed, appears to fall under 'business support services' under Heading No.99859.; 11. Liaising with Customers and potential customers and to collect their product development plans and strategy and "road-maps", as well as their product specifications, and reporting to AM abroad, information obtained through such interactions appears to be connected to the services at Para 10 above as principal supplies, therefore in terms of Section 8 of the Central Goods and Service Tax Act, 2017 read with Section 20 of the Integrated Goods and Service Tax Act, 2017, the said service 'Original compilations of facts or information' which will individually fall under Heading No.998394', / Business Support Service(9985) but as a Composite Supply under Section 13(8)(b) of the IGST Act, 2017, the place of supply of service shall be the location where the services are actually performed. 12. Providing information on products and its functioning or similar such services appears to be connected to the services at Para 10 above as principal supplies, therefore i....
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....n writing to AKI(Applicant). In this the service category is not clearly mentioned, hence, Advance Ruling should not be given for this services; d. Condition IV Payment is received in convertible foreign exchange. The Applicant receives payment in freely convertible foreign exchange i.e. Japanese Yen / United States Dollar. e. Condition V - Supplier of service and recipient of service are not merely establishment of distinct person. Explanation 1 to Section 8 of IGST Act provides that -For the purposes of this Act, where a person has, - (i) an establishment in India and any other establishment outside India; (ii) an establishment in a State or Union territory and any other establishment outside that State or Union territory; or (iii) an establishment in a state or Union territory and any other establishment being a business vertical registered within that State or Union territory, then such establishments shall be treated as establishments of distinct persons. PRAYER In view of the above, it can be construed that in some services (as mentioned above) the Applicant fulfils all the conditions for treating the supply of services as an expor....
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....now whether the supply falls under the category 'support services' or 'intermediary services'. In order to appreciate the issue whether applicant is an intermediary we reproduce below the relevant clauses of the service agreement. "4. Party B (i.e. the Applicant) agrees to conduct from time to time, as and when requested by Party A (being Asahi Kasei Corporation, Japan), research on the matters related to the functions of the holding company, such as corporate accounting, corporate finance, corporate personnel and labor relations, corporate research and development, quality assurance and corporate intellectual property, and provide Party A with its report of the research thereon. 5. Party B agrees to provide Party A from time to time, as and when requested by Party A, with economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and outlook together with similar information concerning such other industries in the Territory (i.e. India or any other mutually agreed territory) as Party A may from time to time request. In the event Party A should require more detailed information than that so p....
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....alue: The value of an intermediary's service is invariably identifiable from the main supply of service that he is arranging. It can be based on an agreed percentage of the sale or purchase price. Generally, the amount charged by an agent from his principal is referred to as "commission". Identity and title: The service provided by the intermediary on behalf of the principal is clearly identifiable. In accordance with the above guiding principles, services provided by the following persons will qualify as 'intermediary services': (i) Travel Agent (any mode of travel) (ii) Tour Operator (iii) Commission agent for a service [an agent for buying or selling of goods is excluded] (iv) Recovery Agent Even in other cases, wherever a provider of any service acts as an intermediary for another person, as identified by the guiding principles outlined above, this rule will apply. Normally, it is expected that the intermediary or agent would have documentary evidence authorizing him to act on behalf of the provider of the 'main service'. Illustration A freight forwarder arranges for export and import shipments. There could be two possible situ....
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....nder the category of the Products and their markets, trends and outlook together with similar information concerning such other industries in the Territory. 3 To provide necessary assistance in liasoning and coordinating activities (including interpreting) to such representatives. 4. To make market surveys of the Products in the Territory and report the results thereof to Party A. 5. All other related services pertaining to above services including, but not limited to, those services with regard to finance, accounting, and patent and legal matters. We clearly find from the scrutiny of clause 15 of the Services Agreement that the relationship between the parties is that of independent contractors meaning that the agreement does not intend to create relationship of principal and agent. The applicant shall not represent itself to be agent of party A and vice-versa. Further applicant have no authority to conclude or negotiate any contracts or secure any orders or maintain any stock of goods on behalf of Party A in this case. On the contrary applicant would provide service on own account to party A to improve functioning of holding company and further augment its business vi....
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....rse of business would depend upon the normal or frequent practices followed in the area of business to which services relate. Such normal and frequent practices adopted in a business can be ascertained from several indicators some of which are listed below - The perception of the consumer or the service receiver. If large number of service receivers of such bundle of services reasonably expect such services to be provided as a package then such a package could be treated as naturally bundled in the ordinary course of business. Majority of service providers in a particular area of business provide similar bundle of services. For example, bundle of catering on board and transport by air is a bundle offered by a majority of airlines. The nature of the various services in a bundle of services will also help in determining whether the services are bundled in the ordinary course of business. If the nature of services is such that one of the services is the main service and the other services combined with such service are in the nature of incidental or ancillary services which help in better enjoyment of a main service. For example service of stay in a hotel is often combined wi....
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....oposes to provide distinct category of services namely A. Services pertaining to research on the matters related to the functions of the holding company such as - corporate accounting, corporate finance, corporate personnel and labour relations, corporate research and development, quality assurance and corporate intellectual property, and provide Party A with its report of the research thereon and B. Services pertaining to information on the markets in the territory includes - i) Economic, industrial and technical information on the products falling under the category of the Products and their markets, trends and outlook together with similar information concerning such other industries in the Territory. ii) To provide necessary assistance in business activities (including interpreting) to such representatives. iii) To undertake market surveys of the Products in the Territory and report the results thereof to Party iv) Ancillary services to all above services, including, but not limited to, those services with regard to finance, accounting, and patent and legal matters." From the nature of services it is evident that these services are n....
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....owhere else classified Sr.no. Chapter, section, heading or group Service code (tariff) Service description 356 Group 99839 Other professional, technical and business services 357 998391 Specialty design services including interior design, fashion design, industrial design and other specialty design services 358 998392 Design originals 359 998393 Scientific and technical consulting services 360 998394 Original compilations of facts or information 361 998395 Translation and interpretation services 362 998396 Trademarks and franchises 363 998397 Sponsorship services and brand promotion services 364 998399 Other professional, technical and business services nowhere else classified Sr.no. Chapter, section, heading or group Service code (tariff) Service description 345 Group 99837 Market research and public opinion polling services 346 998371 Market research services 347 998372 Public opinion polling services ....
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....ort services" falling under HSN code 9985 or "Intermediary service" classifiable under HSN code 9961 / 9962? Applicant entered into 'Marketing Service Agreement' dated 1st December 2012 with Bioprocess Division of Asahi Kasei Medical Co. Japan (in short AM). As per the preamble the services are proposed to be provided with the sole intention to develop/ argument sales of bioprocess consumables and for that purpose AM desires to secure market support services offered by the Applicant. Applicant proposes to provide services which shall comprise of following activities. "a) Conducting market surveys and providing the service recipient with the information on Indian market trends and features so as to assist in determining the nature and scope of the Indian market potential; b) Assisting the service recipient in the adaptation and implementation of its advertising policy; c) Assisting the service recipient in conducting sales prospection through participation in industry events such as scientific gatherings, exhibitions, trade shows and the like; d) Liaising with Customers and potential Customers and to collect their product development plans and strategy and road-maps",....
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....rincipal and agent. By this agreement applicant shall not carry out any act that will be binding on AM, such as conclusion of contracts, acceptance of sales order, invoicing, determination of sales prices, rebates or discounts, resolution of customers complaints or settlement or disputes with the customers. On this factual matrix we discuss whether the provision of services constitute 'intermediary' as defined under section 2(16) of IGST Act. The definition is already reproduced in preceding para of this ruling. The concept of intermediary under the GST Act is substantially identical to the concept of intermediary under the erst while service tax regime. This concept has been explained in the Education Guide issued by CBEC in the year 2012 which we have already reproduced in this ruling. We find from the scrutiny of Marketing Services Agreement that the relationship between the parties is that of independent contractors meaning that the agreement does not intend to create relationship of principal and agent. The applicant in no way carries out activities such as conclusion of contracts, acceptance of sales orders, invoicing, determination of sales prices, rebate, discounts, r....
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....ssistance to AM in conducting said activities and not actual provision of services on his own account. In view of this the applicant's case is squarely covered by the decision in case of M/S. Godaddy sited supra with Marketing Research as the principal supply. This finding of ours is based on the observation that conducting market survey and information on Indian market trends are main services that determine the nature and scope of Indian Market Potential for recipient of services. With regards to the classification of services under the rate notification 11/2017 as amended from time to time, and the annexure of classification of services we find following entries that are relevant for the present purpose. Sr.no. Chapter, section, heading or group Service code (tariff) Service description 345 Group 99837 Market research and public opinion polling services 346 998371 Market research services 347 998372 Public opinion polling services From the perusal of above table and the finding by us as above, we hold that the services the applicant proposes to provide would fall under Group 99837 as Market Research Servi....