The issue involved determination of whether the applicant is required to obtain separate GST registration in the State of Rajasthan for execution of a turnkey substation project.

M/s. Gopi Damodaran is a propreitary concern providing various services including Leasing out of properties. The Applicant is the owner of a residential property situated at SF No.1056/1A2/SITE No.1, Aarudhra Qunita, Kalapatti East, Coimbatore where the building is yet to be leased out as Hostel Facility by way of a Rental Agreement renewable yearly. The Applicant would like to provide the residential property on lease to a prospective tenant intending to run hostel for students and working person with a philanthropic motive and purpose for providing a safe, secure, and a "home away from home" environment for college students and working persons.

The Applicant is currently in the process of construction of a mall/commercial complex with the intention of leasing/renting out the entire premises. For this purpose, the applicant will incur expenses on various goods and services, including construction materials, contractor services, architect fees, etc. The applicant wishes to claim ITC on such inputs and input services used in the construction of the building intended to be rented out.

The applicant is engaged in supply of food and beverages to Corporates. The applicant neither prepares the food and beverages nor serves them in the Client's canteen; they procure it from third-party sources in a packed condition and supply it to their clients through outsourced logistics provider. The serving of food in the canteen is managed by the client.

M/s. Kangayam Coconut oil Manufacturers Association, having principal place of business at No. 171, Tiruppur Road, Kangayam - 638 701 (hereinafter called as the "Applicant") are registered with GSTIN 3ЗААЕАКK3571F1ZV under the goods and services tax Act. They have filed application for advance ruling through online portal under Section 97 of the CGST Act, 2017, and corresponding provisions under the Section 97 of TNGST Act, 2017 vide ARN AD3310190030312, dated 26.10.2019.

 2) But, application has not been filed manually as mentioned in the Rule 107A of the CGST Rules, 2017. Hence, a notice was issued on 22.10.2025 and 21.11.2025, to the applicant requesting to file manual application with proof for payment of application fee of Rs.5000/- under SGST Act and Rs.5000/ under CGST Act along with supporting documents/records as applicable. However, the applicant has not filed the manual application along with payment proof. 

3) On verification of GST portal, the applicant has paid the fee of Rs.5000/- under SGST Act, 2017 only, and not paid the fee of Rs.5,000/- under CGST Act 2017 as prescribed under Section 97(1) of CGST Act 2017. Hence, the application is liable for rejection under Section 98(2) of CGST 2017. 

4) On receipt of the notice from this Office, the applicant vide their letter dated 02.12.2025, have requested to permit them to withdraw the Advance Ruling Application, as their issue was resolved.

A. Admissibility of Input Tax Credit (ITC) on Direct Expenditures for Second-Hand Vehicles. (i) In view of the Notification No. 8/2018-Central Tax (Rate) dated 25th January 2018, the applicant would like to get clarification as to whether the input tax credit would be available on inward supplies of goods or services which are in the nature of direct expenditures like spare purchases, repairs and refurbishment costs of vehicles, etc., except on purchase of old or used motor vehicles as mentioned in para 2 of the notification.

 B. Admissibility of Input Tax Credit (ITC) on Other Common Business Expenses and Capital Goods. (ii) In view of the Notification No. 8/2018-Central Tax (Rate) dated 25th January 2018, the applicant would like to get clarification as to whether the input tax credit would be available on inward supplies of other goods or services except on purchase of old or used motor vehicles as mentioned in para 2 of the notification. That is, whether credit of input tax available on inward supplies of goods or services like office/ showroom rent, telephone, advertisement, professional charges, capital goods, etc., except that on inward supply of old or used motor vehicles.

(i) Whether GST is applicable on the centage charges collected being the centage charges levied for consulting services provided to a Government entity which is covered under Article 243G/243W of the Indian constitution (12th schedule) 

(ii) Whether the company can claim refund of GST already paid for the year 2017-18 onwards?

withdrawal

a. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Jivvij Samaara Black Tea Leaf 5 kg Pouch being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above? 

b. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Samaara Premium Ctc Leaf Black Tea 250 gms Jar, 500 gms Jar & 900 gms Jar being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above?

 c. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Premium Lemon, Jasmine and Mint Green Tea being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above? 

d. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Herbal Tea (Chai Vedic) being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above? 

e. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Pyramid Tea Bags being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above? 

f. Whether the supply of Jivvij Samaara Masala Instant Premix Tea sachets with Flavoured Black Tea (Saffron Tea & Rose Tea) being the principal supply will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above? 

g. If future, if we supply Jivvij Samaara Masala Instant Premix Tea sachets with any other product having rate of tax at 5% being the principal supply, will be considered as the “Composite Supply” or “Mixed Supply”? What will be the rate of tax for the above?

 h. What will be HSN code to be used by us in above case

i. Whether any significant difference is there between "Metalized Yarn" and "Metallic Yarn" or both are one and same and what will be their Classification? 

ii. Whether the Supply made of Badla / Imitation Jari / Metallic Yarn made from Micro Slitting process done on Plain Polyester Film or Metalized Polyester Film or Metalized & Lacquered Film will fall under merit classification under HSN 56050090 or 56050020?

 iii. If the answer to Question No. 2 mentioned above is 5605 0020, then whether the Applicant is eligible for concessional rate of 5% w.e.f. 27.07.2023? 

iv. If the answer to Question No. 2 mentioned above is 5605 0020, then whether the Applicant is eligible for Refund on "Polyester Yarn", Lacquered Film, Chemicals, Packing Material, and Coal etc. till Dt. 19.08.20237?

 v. If the answer to Question No. 2 mentioned above is 5605 0090, then whether the Applicant is liable to Rate of 12%? 

vi. If the answer to Question No. 2 mentioned above is 5605 0090, then whether the Applicant is eligible for Refund on "Polyester Yarn", Lacquered Film, Chemicals, Packing Material, and Coal etc.?