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2024 (5) TMI 256

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....oorthy For the Petitioner : Mr. G. Natarajan For the Respondent : Mr. B. Ramanakumar, Sr. SC ORDER An assessment order dated 28.12.2023 is the subject of challenge in this writ petition only insofar as it dealt with the imposition of GST on vouchers. 2. The petitioner is engaged in the business of managing and implementing various reward programmes for its corporate clients. This includes buy....

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....ion to vouchers by relying on sub-section (4) of Section 12. By pointing out that the petitioner is not a supplier of the goods underlying the vouchers and that the role played by the petitioner is limited to that of an intermediary, which procures vouchers from suppliers and thereafter sells such vouchers to its clients, he contended that the case of the petitioner is squarely covered by the judg....

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....as regards the issue relating to vouchers, is as under: "2. The assessee has given an elaborate reply in which they claim that a. Vouchers are neither good nor services - It is mere Actionable Claim covered under Schedule III b. Supply of Unidentified Vouchers - Time of Supply would not attract c. Notice acting in the nature of pure agent-Value of Vouchers should be excluded from valuati....

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....ST Act. Conspicuous by its absence in the impugned order, is the recording of reasons as to why the contentions of the petitioner were rejected. Since the impugned order is unreasoned in this respect, such order is unsustainable. 8. For reasons set out above, the impugned order is set aside only insofar as it relates to the imposition of GST on vouchers. As a consequence, this issue is remanded f....