CBEC explains taxability of
GTA services under GST regime, states that issuance of consignment note is a
sine-qua-non for supplier of service to be considered as GTA and that services
provided by such individual transporters who do not issue a consignment note
will be exempt under Notification No. 12/2017-Central Tax (Rate); Explains that
GTA service can be taxed at 5% subject to condition that ITC of goods &
services used therein has not been taken, whereas GTA can opt to discharge
liability at 12% with no restriction on ITC availment; Where recipient is a
factory / society / cooperative society / person with GST registration / body
corporate / partnership firm / casual taxable person, liability to pay GST
devolves on such recipient unless GTA avails forward charge option (12%), but
in all other cases where recipients do not fall in said categories, liability
will be on GTA service supplier; Definition of ‘GTA’ includes not only the
actual transportation of goods but any intermediate/ancillary service provided
in relation thereto like loading/unloading, packing/unpacking, trans-shipment
and temporary warehousing and hence, liable to GST unless they are provided as
independent activities; States, “The law recognises that pure
transportation of goods services are mostly provided by persons in the
unorganised sector and hence has specifically excluded such operators from the
tax net” : CBEC
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