E-commerce operator status for voucher app; no reverse charge under s.9(5); TCS liability and state GST registration under s.52

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....AAR held that the Applicant's voucher-collection activity, conducted via its Freedeem app and involving receipt of consideration on behalf of merchants, constitutes electronic commerce and renders the Applicant an e-commerce operator under the GST Act. The Applicant is not liable under reverse charge mechanism u/s 9(5) because its services are limited to voucher/coupon facilitation and collection and do not fall within the notified services under s.9(5). The Applicant is, however, required to collect TCS under s.52 on net taxable supplies collected through its platform and must obtain separate GST registration for TCS purposes in each State where supplies are effected. The question on TCS vis-à-vis payments to registered versus unregistered merchants was not adjudicated.....