Authority for Advance Ruling (AAR)

Q.1. Whether or not, on the facts and in the circumstances of the case, the supplies of Coursera User License made by the Petitioner to OSDA is classifiable under Heading 9992 (Education Service)?

 Q.2 Whether or not, on the facts and in the circumstances of the case, the Exemption under SLNo.72 of Notification No.12/2017-Central Tax (Rate) Dated 28-06-2017, as amended, is available to the Petitioner for supplies made by the Petitioner to OSDA ?

 Q.3 Whether, on the facts and in the circumstances of the case, the supplies made by the Petitioner is more appropriately classifiable under Heading 9973 (Leasing or Rental Services)? 

Q.4 Alternatively, whether, on the facts and in the circumstances of the case, the supplies of User License to access online content of Coursera, proprietary digital platform made by the Petitioner is classifiable under Heading 9984 (Online Content Services)?

What is the prevailing GST rate (CGST and SGST) for sale of Used Gunny Bags received during purchase of Raw materials for Cattle feed Manufacturing process and sold as Scrap?

1. Whether rent paid by the applicant (a voluntarily registered person dealing exclusively in exempted goods) to an unregistered landlord for commercial space is liable to GST under the Reverse Charge Mechanism? (a) If RCM applies, whether the liability arises under Section 9(3) or Section 9(4) of the CGST Act, 2017? (b) If RCM does not apply, what is the legal basis for exemption? 2. If the Applicant registers as a composition dealer for a furniture manufacturing unit, will the applicant be liable to pay GST under the RCM on purchases of wood (a key raw material) from unregistered dealers under Section 9(3) or Section 9(4) of the CGST Act, 2017?

What is the prevailing GST rate (CGST and SGST) for sale of Used Gunny Bags received during purchase of Raw materials for Cattle feed Manufacturing process and sold as Scrap?

1.Whether the sale of bakery products such as cakes, pastries, sandwiches, savouries, biscuits, slice cakes, bread, rusk and other ready-made items, which are fully manufactured at the Corlim factory and sold through bakery outlets without any cooking, preparation or processing, constitutes a supply of goods under GST ?

 2. Whether preparation and sale of semi-finished goods such as pizzas at the outlets, wherein pizza base and toppings are supplied from the factory and are blended/prepared at the outlet upon customer order, constitutes restaurant service? 

3. Whether the Applicant is permitted under GST Law and basis the principles laid out in circular 164-para 3 and para 4 to 1. charge GST as goods for items sold without preparation, and 2. Charge GST as services for items involving preparation/ cooking subject to maintain a separate billing series, accounting records etc.?

1. Whether the activity of construction/ developing commercial units on vacant plot of land being acquired as capital asset out of surplus funds be treated as in the course or furtherance of business in respect of income generated on account of following transactions: 

a. Sale of commercial units to prospective buyers 

b. Rent received on leasing of commercial units 

2. If yes, whether input tax credit be eligible for inputs & input services used for the construction of commercial units in case of above transactions i.e. a. Sale of commercial units to prospective buyers b. Rent received on leasing of commercial units

1. The Applicant supplies imported goods stored in his bonded warehouse to foreign-going vessels, Indian Navy Ships and Indian Coast Guard Ships. Will these outward supplies be treated as Export Sales (Zero-rated Supply) under GST?

 2. If these outward supplies are treated as Export Sales, then under LUT, can these items be exported without payment of IGST?

1. Whether supply of flats to MHADA identified customers after Occupancy Certificate (OC) is exempted from levy of GST being it is sale of immovable property which is not liable to GST? If it is treated as taxable supply next query is, 

2. In these circumstances if it is treated and held as taxable supply assuming that being "services of works contract service" is rendered to MHADA identified 20% flats then what is the value of supply for GST? Whether it is MHADA dictated value of supply or Market value of supply?

1. Whether the supply being made is pure service or composite supply, where supply of goods does not exceed more than 25% of the value of the supply? 

2. Whether the recipient is Government, Local Authority, Governmental Authority or Government Entity? 

3. Whether supply is being made in relation to any function entrusted to a Panchayat or a Municipality under the Constitution? 

4. Whether the applicant is eligible for exemption of services being provided by way of pure service or composite supply based on Entry 3A w.e.f. 25.01.2018 vide Notification No. 2/2018-CT(R) which needs to be clarified by way of Advance Ruling?

Applicability of a notification issued under the provisions of the Act. Specifically, classification of bio compostable carry bags under Chapter 39 (HSN 39232990) and whether they are covered under Schedule I of Notification No. 9/2025 - Central Tax (Rate) attracting 5% GST.