EPF and ESI reimbursement u/s 15 of CGST Act attracts 18% GST due to lack of pure agent status.

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....Valuation - Section 15 of CGST Act - reimbursement of Employee Provided Fund & ESI - there is no contractual agreement with the recipient of supply to act as his pure agent to incur expenditure or costs in the course of supply of services as the Work Order dated 22.02.2017 simply provides that after deposit of EPF and ESI in the concerned department, the reimbursement will be done as per rule and there is no mention in the said Work Order that the contractor will deposit EPF and ESI as the pure agent of the applicant. - GST is liable to be paid @18% on the reimbursement of EPF and ESI contribution as the same is liable to be included in the value of supply - AAR....