9911796707
TMI Blog2019 (7) TMI 1105X X X X Extracts X X X X X X X X Extracts X X X X ..... ting service - The consideration for the services rendered by the applicant will be paid upon successful investment/ repatriation by the investor. The applicant does not provide any services on his own but is acting as an intermediary in the subject case. Whether the Marketing services to be provided by the Applicant will be an export of services as defined under Section 2(6) of the Integrated Goods and Services Tax Act 2017? - HELD THAT:- The services are provided to the Consultant Manager situated in foreign territory fall in Sections 13(8b) of Section 13 of the IGST Act, 2017. Hence the place of supply of service is within India and therefore the service rendered by the applicant is not export of service as condition (iii) of Section 2(6) of IGST Act is not fulfilled. Whether the Handholding services to be supplied by the Applicant under the Foreign Immigration Advisor Agreement constitute a supply of Support services falling under SAC 9985 or Intermediary service classifiable under SAC 9961 / 9962 or any other heading? - export of services or not - HELD THAT:- The applicant is providing intermediary service in the name of hand holding service and not 'support se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y in providing marketing and advisory services in relation to the Employee Based Immigration: 5th Reference Program notified by the United States Citizenship and Immigration Services (hereinafter referred to as the EB-5 Program ). The EB-5 Program envisages that an investor is eligible to a permanent residence permit in the United State of America subject to an investment of US$ 500,000 and job-creation in a commercial entity or investment fund, commonly referred to as a Regional Centre or a Company , which is approved and recognized by the Government of the United States of America. The Applicant wants to provide certain services in the nature of marketing and intelligence to the Consultant Manager acting for the Regional Centre or Company enabling them to receive investments from prospective investors. The scope of work under this Agreement titled as Foreign Immigration Advisor Agreement can broadly be stated as below: (i) Marketing services a. Collecting and analysing information i.e. market analytics, intelligence, preparing and drafting reports, strategy and providing leads to the Consultant Manager; b. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y obligation of any kind or nature whatsoever on behalf of the other party. Neither shall have the authority to conclude or negotiate any contracts or secure any orders on behalf of each other. As a matter of fact, the Applicant will never negotiate or enter into any contract with any prospective customer on behalf of the Consulting Manager for the investment. In all the cases, the terms of investment, the nature of investment, the investment project and the investment vehicle are decided basis the interactions solely between the Consulting Manager and the prospective investor. In fulfilment of its obligation towards marketing services, the Applicant will undertake inter alia the following activities: (i) Plan and conduct market surveys to identify the market and prospective investors in relation to the EB-5 program for the Consultant Manager; (ii) Prepare reports, marketing plans, market intelligence and compile list of prospective investors for the Consultant Manager; (iii) Formulate a strategy plan for the benefit of the Consultant Manager; (iv) Address queries of the Consultant Mana ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... namurthy Co. Vs. J. Ramanujan and Ors. (AIR 1961 AP 408)]. = 1960 (7) TMI 66 - ANDHRA PRADESH HIGH COURT b. Concise Law Dictionary (2008 Edition): - A middlemen or an agent who for a commission on the value of the transaction, negotiates for others the purchase or sale of stocks, bonds, commodities, or property of any kind; or who attends to the doing of business for another; c. Law Lexicon Dictionary (Sumeet Malik): - An agent employed to make bargains and contracts between other persons in the matters of trade, commerce and navigation, by explaining the intentions of both the parties and negotiating in such a manner as to put those who employ him in a condition to treat together personally; (2) and more commonly an agent employed by one party only to make a binding contract with another. d. Shorter Oxford English Dictionary (Deluxe Edition): - A person who acts for another un business, politics, etc.; e. Section 182 of the Indian Contract Act 1872: - An Agent is a person employed to do any act for another or to represent another in dealings with third persons; f. Concise Law Dictionary (2008 Edi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... SC/0884/2010]. = 2010 (10) TMI 19 - SUPREME COURT Similar view has been affirmed in the following cases: i. CIT Vs. Rani Tara Devi [2013 (355) ITR 457 (P H)]; = 2013 (3) TMI 53 - PUNJAB HARYANA HIGH COURT ii. Commissioner of Income tax, Udaipur Vs. Mcdowell Co. Ltd. [MANU/SC/0964/2009] = 2009 (5) TMI 27 - SUPREME COURT 9. In view of the above, it is submitted that the scope of the term any other person, by whatever name called will include a person in the same genus as that of an agent or a broker. Thus, on a combined reading of the dictionary meaning of the terms broker and agene' along with the aforementioned judicial precedents, it can be construed that the only persons appointed in representative capacities can be covered within the scope of the first limb of aforesaid definition (Intermediary). 10. As per the second part of the definition, an intermediary Arranges or facilitates the supply of goods or services or both, or securities between two or more persons . It is further submitted that the service heading 9961 / 9962 refers to intermediary service in wholesale trade and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... behalf of the foreign entity. As per the plain words of the Foreign Immigration Advisor Agreement, the Applicant will provide services to the Consultant Manager of his own volition and hence, the services to be supplied by the Applicant to the service recipients fails to comply with the second limb of the definition of the term intermediary . 14. The activity of sales promotion and marketing are not selling of goods and therefore, such activities would not be classifiable under the said heading. The activities of the Applicant will be in relation to market survey, market intelligence and leads, sales promotion, and customer relation. The Applicant will never participate in the actual sales negotiation or profess to act on behalf of the Consultant Manager or help in concluding the investment by the prospective investor. In other words, the Applicant will not be engaged as an intermediary. 15. At this juncture, it is also submitted that the mere fact that the amount payable by the Consultant Manager for the Marketing services is deferred till successful investment/ repatriation by the investor does not also make it intermediary services. This is for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... immovable property, security, testing and analysis; [Negative List regime] 18. From the above, it can be construed that marketing services, advertisement and promotion services, customer relationship management, evaluation of prospective customers, etc. would qualify to be in the nature of support services only. 19. Thus, plainly, the supply of services to be provided by the Applicant would be classified under tariff entry 9985 as Business Support Service . Question 2:- Whether the Handholding services to be supplied by the Applicant under the Foreign Immigration Advisor Agreement constitute a supply Of Support services falling under SAC 9985 or Intermediary service classifiable under SAC 9961 / 9962 or any other Statement of facts having a bearing on the question The scope of the services to be provided by the Applicant to the Consultant Manager have been provided under the agreement. In brief, this relates to the second tranche or bucket of services, viz., once the investor has confirmed the proposed investment. In this regard, the Applicant provides hand-holding services suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces or both, or securities between two or more persons; c. But does not include a person supplying such goods or services or both or securities on his own account. 4. For avoiding repetition and to maintain brevity, the Applicant does not reproduce the submissions but humbly prays that the submissions made in respect of Question No. 1 be treated as part and parcel of the present question. 5. In the instant case, the Applicant and the Consultant Manager will act as independent contractors in carrying out the handholding service. Moreover, the Applicant and the service recipient will have no authority to create nor will they assume any obligation on behalf of each other. The services rendered by the Applicant are limited in this respect. Although the Applicant assists the person of interest in filling of the forms, providing direction to get the necessary security Clearances, and getting together all the financial information required as per the Consulting Manager, these duties are purely procedural and do not at any point in time extend to facilitating the investment itself. In simpler terms, the applicant is acting independently for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovides a clause that the Parties do not intend to create any agency or similar relationship. Further, although the consideration is contingent in nature that is for the purposes of determining the timing of payment and quantum thereof. The consideration does not in any way change the nature of services to be provided by the Applicant. Per the plain words of the Foreign Immigration Advisor Agreement, the Applicant will provide services to the Consultant Manager of his own volition and hence, the services to be supplied by the Applicant to the service recipients fails to comply with the second limb of the definition of the term intermediary . 9. Since the services to be provided by the Applicant will be as an independent contractor, the Applicant will automatically fall within the exclusion provided in the third limb of the definition. In view of the above, the applicant will not be construed as an intermediary in terms of Section 2(13) of the IGST Act. 10. The Applicant will never participate in the actual sales negotiation or profess to act on behalf of the Consultant Manager or help in concluding the investment by the prospective investor. In other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ties, pantry and security; [Pre-negative List regime] Section 65B(49) support services means infrastructural, operational, administrative, logistic, marketing or any other support of any kind comprising functions that entities carry out in ordinary course of operations themselves but may obtain as services by outsourcing from others for any reason whatsoever and shall include advertisement and promotion, construction or works contract, renting of immovable property, security, testing and analysis; [Negative List regime] 13. From the above, it can be construed that the services of handholding and assisting in in filling forms, and correct documentation for the proper consideration of application, evaluating prospective customers, etc. would qualify to be in the nature of support services only. 14. Thus, the supply of services to be provided by the Applicant would be classified under tariff entry 9985 as Business Support Service . Question 3:- Whether the Marketing services to be provided by the Applicant will be an export of services as defined under Section 2(6) of the Integ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and therefore, their registered place of business will be their registered address (i.e. outside India). c. Condition III - Place of supply of service is outside India From (a) and (b) above, it appears that while the service provider will be situated in India, the service recipient will be located outside India. In order to determine the place of supply, I refer to Section 13 of the IGST Act which provides for the place of supply of services in case where either the service recipient or the service provider is situated outside India. The services to be provided by the Applicant are in the nature of Support services classifiable under HSN code 9985. The place of supply in the instant case would therefore be determined as per the general rule i.e. as per Section 13(2) of the IGST Act. Applying the above to the present case, the place of supply of services shall be the location of the Consultant Manager i.e. outside India. Further, it is pertinent to note that there is no consideration flowing from the Indian customer to the applicant and the beneficiary of the services rendered is directly the Consultant Manager. d. Condi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of service are not merely establishments of a distinct person in accordance with Explanation 1 in section 8; 2. Each of these conditions have been discussed in detail hereunder; a. Condition I - Supplier of service is located in India For this, I refer to the definition of the term location of the supplier of services as defined under section 2(15) of the IGST Act. As per the said definition, where a supply has been made from a place where the person has obtained registration, the location of the supplier shall be such place of business. In the instant case, the Applicant will provide service from Maharashtra for which it will obtain GST registration. Consequently, the location of the supplier of service shall be Maharashtra i.e. in India. b. Condition II - Recipient of service is located outside India The term location of the recipient of services has been defined under section 2(14) of the IGST Act. As per the said definition, if a supply has been received from a registered place of business or registered fixed establishment, the location of the recipient shall be the respective place of business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... legal persons. The term person has been defined to include a Company. In the instant case, the service recipient i.e. Consulting Manager is not an establishment formed by the Applicant and consequently, it cannot be treated as in establishment of a distinct person. 3. In view of the above, it can be construed that the Applicant fulfils all the conditions for treating the supply of services as an export of services in terms of Section (6) of the IGST Act. Therefore, the answer to Question No. 3 above should be in affirmative. Additional submissions on 13.05.2019 WRITTEN SUBMISSIONS ON BEHALF OF THE APPLICANT Most respectfully sheweth: 1. At the outset, the Applicant humbly thanks the Hon'ble Authority for granting an opportunity of personal hearing. In furtherance of the same, the Applicant is now filing the present submissions for consideration of the Hon'ble Authority. 2. At the outset, it is submitted that the submissions herein are without prejudice, and in addition to the averments taken in the application for advance ruling. Facts in brief ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng such meetings, Applicant merely act as an interpreter without getting involved in the negotiation. The Applicant never represent any party in any capacity whatsoever. 6. Once the perspective investors and Consultant has finalised their deal, as part of Handholding service, the Applicant helps the investor in filling forms, obtain necessary documents as required by the Consultant Manager and allied activities. For such services, the Applicant does not get any consideration from the investor. 7. Once all details are complete and the amount is remitted to the Company, the Applicant is paid for the Marketing services and Handholding service by the Consultant. Questions for determination raised 8. In the above background, the Applicant has approached the Hon'ble Authority for a ruling on the following questions: a. Whether the Marketing services to be supplied by the Applicant under the Foreign Immigration Advisor to the Consultant Manager constitutes a supply of Support services classified under SAC 9985 or Intermediary service classifiable under SAC 9961 / 9962 or any other heading? ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y other person to a customer are liable to service tax under section 65(105)(zm). The expression 'any other person' appearing in section 65(105)(zm) is to be read ejusdem generis with the preceding words . The expression 'other financial services' appearing under section 65(12)(a)(ix) is a residuary entry and includes; those services which are normally rendered by banks or financial institutions. 4. Hence, banking and other financial services provided by a banking company or a financial institution or a nonbanking financial company or any other service provider similar to a bank or a financial institution are liable to service tax under section 65(105)(zm) of the Finance Act, 1994. Department of Posts is not similar to a bank or a financial institution and hence does not fall within the category of any other similar service provider. (Emphasis supplied) 11. Without prejudice to above, it is submitted that if the intention of the legislature was to cover persons of all hue and cry under the phrase 'any other person then words preceding thereto namely broker, an agent becomes redundant as also the wo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case college admit the student, the said college pays commissioner/ fee to the appellant. Further the people wishes to settle in Canada as investors borrow loan from foreign based banks. The appellant refers their case to foreign banks and in return gets commission from bank if money is landed to such investment. 8. In these set of facts, following issues emerges: (A) Whether the appellant is intermediary in terms of Rule 2(f) of POPS Rules, 2012 or not? 10. We find that the appellant is nowhere providing services between two or more persons. In fact, the appellant is providing services to their clients namely bank /college /university who are paying commission/fees to the appellant. The appellant is only facilitating the aspirant student and introduced them to the college and if these students gets admission to the college, the appellant gets certain commission which is in nature of promoting the business of the college and for referring investors borrow loan from foreign based bank to the people who wishes settled in Canada on that if the deal mature, the appellant is getting certain commission. So the na ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... support services to WWD US and on his own account. Therefore. applicant is not an intermediary and the service provided by hint is not intermediary service . Further, during arguments, applicant drew our attention to one of the illustration given under Paragraph 5.9.6 of the Education Guide, 2012 issued by C, Relevant portion is extracted as under; Similarly, persons such as call centers, who provide services to their clients by dealing with the customers of the client on the client s behalf, but actually provided these services on their own account', will not be categorized as Intermediaries. Applicant relying on above paragraph submitted that call centers, by dealing with customers of their clients, on client's behalf, are providing service to their client on their own account. Similarly, applicant is providing business support service such as marketing and other allied services like oversight of quality of third party customer care centre operated in India and payment processing services, on behalf of GoDaddy US. Therefore, these services provided by the applicant to GoDaddy US cannot be categorized as intermediary or services, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his principal is referred to as commission . Identity and title: The service provided by the intermediary on behalf of the principal is clearly identifiable. Even in other cases, wherever a provider of any service acts as an intermediary for another person, as identified by the guiding principles outlined above, this rule will apply. Normally, it is expected that the intermediary or agent would have documentary evidence authorizing him to act on behalf of the provider of the 'main service'. In simple term intermediary means a person who acts to arrange an agreement between two or more persons as a mediator or a link. In the present case as per services agreement, applicant has undertaken following activities namely- 1. Research on the matters related to the functions of the holding company, such as corporate accounting, corporate finance, corporate personnel and labour relations, corporate research and development, quality assurance and corporate intellectual property, and provide Party A with its report of the research thereon. 2. To provide with econom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... way change or amend or influence the agreement between the Consultant Manager and interested individual. 20. Further to the above, it is submitted that the order dated 26 February 2019 of In Re: Vservglobal Private Limited = 2019 (4) TMI 1543 - APPELLATE AUTHORITY FOR ADVANCE RULING, MAHARASHTRA (Annexure 6 ) by the Hon'ble Appellate Authority for Advance Ruling is inapplicable to the present case since the facts are entirely different. In Vservglobal supra, the extent of duties provided therein included creating purchase orders, sales contracts, ensure transportation and details thereof, liaising with authorities for pre-shipment inspections and the like. Activities like liaison with various stakeholders, creation of purchase order, sales contract, and bill of lading, payment processing on behalf of customer etc cannot be performed by Vservglobal without authority from the customers to act as an agent, and therefore, rightly they have been held as intermediary by the Hon'ble authority. 21. In the present facts, the Applicant is not concerned and connected in any way with the execution of the order or the investment. The A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iary. Questions (c.) and (d.) 25. Basis the submissions supra, it is submitted that the Applicant is not a provider of intermediary services. On the contrary, and as detailed in the application for advance ruling, the Applicant is a provider of business support services. 26. Consequently, the Place of Provision is the location of the recipient of service, i.e., United States of America. The Applicant will be paid in foreign exchange for the services rendered. Lastly, as the supplier of services (Applicant) is located in India and recipient of services is located outside India (Consultant Manager), all requirements for export of service under Section 2(6) of the IGST Act are satisfied. 27. Therefore, the marketing services as also the hand-holding services are an export of service. 03. CONTENTION - AS PER THE CONCERNED OFFICER The submission, as reproduced verbatim, could be seen thus- The applicant, viz, Mayank Jain, is an individual resident of India (hereinafter referred to as the Applicant), who envisages to provide the services in relation to the Employee Based I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 39; personal information and such documentation necessary for his/her investment and also towards completion of the immigration process for such qualified investors. 2. The consideration towards the services provided by the Applicant to the Company, Consultant Manager, shall be received by them by way of payment of a 'Fee' (in USD), towards the advisory services provided by the Applicant upon successful confirmation of a proposed investment by a qualified investor, and a further payment of 'Approval Fee' (in USD), upon receipt of final approval of such investment from authorities. 3. Therefore, from the above, it is evident that the Applicant acts as an intermediary between the Company and the prospective qualified investors in India. Definition of 'intermediary' is contained under section 2 (13) of Integrated Goods and Service Tax Act, 2017 and the same is reproduced hereunder for ready reference ; intermediary means a broker, an agent or any other person, by whatever name called, who arranges or facilitates the goods or services or both, or securities, between two or more persons, but does not include a perso ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Applicant is authorised by the Company to act and represent them on their behalf and carry out such functions viz: marketing of the EB-5 program in India to prospective investors and to perform the immigration and administrative related duties on behalf of the Company. Accordingly, the services being provided by the Applicant do not appear to be on Principal to Principal basis, but it appears that the Applicant by way of acting on behalf of the Company for performing the immigration and administrative related functions of the Company towards their prospective investors, is essentially acting as an agent/representative of the company in India. 9. In the case of Global Reach Education Services Pvt. Ltd. [2018 (12) G.S.T.L. 387 (A.A.R. - GST)], = 2018 (4) TMI 808 - AUTHORITY FOR ADVANCE RULING, WEST BENGAL i t has been held that marketing services provided to global universities, are intermediary services. The appellate authority of Advanced Ruling in the said case [2018 (15) G.S.T.L. 618 (App. A.A.R. - GST)] have further expanded the definition and held that even ancillary services falls within the meaning of intermediary services. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he basis of the place of supply of the said goods or service. 2. The Provision of place of supply of service in case of intermediary are specifically contained under section 13 (8) of Integrated Goods and Service Tax Act, 2017 and the same is summarized hereunder for ready reference Section 13 (8) of the IGST Act states that - - The place of supply of the following services shall be the location of the supplier of services, namely: (a) Services that are supplied by a banking company or a financial institution or a nonbanking financial company to its account holders; (b) Intermediary services ; (C) Services that consist of hiring of the means of transport up to a period of one month. Such means of transport includes yachts but excludes aircrafts and vessels. Hence on the basis of above the provisions of section 13 (8)(b), it is pretty clear the place of supply of the intermediary service would be location of the supplier of services, i.e the intermediary. In the instant case, the location of the Applicant (the intermediary) is the taxable territory of India. Further, it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... igration Program notified by the United States Citizenship and Immigration Services (hereinafter referred to as the EB-5 Program ). The EB-5 Program envisages that an investor is eligible to a permanent residence permit in the USA subject to an investment of US$ 500,000 leading to job-creation in a commercial entity or investment fund, commonly referred to as a Regional Centre or a Company , approved and recognized by the Government of the United States of America. It has been submitted that a 'Consultant Manager' represents the Regional Centre or a Company in the USA. The applicant will provide certain services in the nature of marketing and intelligence to the Consultant Manager acting for the Regional Centre or Company enabling them to receive investments from prospective investors. The scope of work under this Agreement titled as Foreign Immigration Advisor Agreement . The details of services to be provided by the applicant is mentioned in his application and includes various services which will enable the applicant to market the EB-5 Program in India to prospective investors in India. Towards this end they will be entering into a Foreign Imm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the scope of the services rendered to the Consultant Manager includes planning and conducting market surveys to identify the market and prospective investors in relation to the EB-5 program for the Consultant Manager; Prepare reports, marketing plans, market intelligence and compile list of prospective investors for the Consultant Manager; Formulate a strategy plan for the benefit of the Consultant Manager; Address queries of the Consultant Manager in relation to the above, as and when raised by the Consultant Manager; and Conduct sales prospection through necessary participation in industry events and provide spotlight to the EB-5 program Thus we find that in this case, once the Indian investor makes a decision to invest in the US, he contacts the applicant who provides services to the Indian investor and also facilitates meeting/contact between both of them- Indian investor through the applicant contacts the investment consultant in America for advice as to where to invest and the formalities to be fulfilled for the investment under the EB-5 Scheme. For that purpose the Consultant manager appoints an agent or a facilitator who will facilitate such service. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ods or services or both, or securities, between two or more persons but does not include a person who supplies such goods or services or both or securities on his own account; The above definition is examined in detail in the below table Sr. No. Intermediary Definition Explanation 1 means a broker, an agent or any other person, by whatever name called The Applicant is the 'any other person, by whatever name called 2 who arranges or facilitates the supply goods or services or both, or securities, between two or more persons The Applicant facilitates the investment permanent residence advisory service provided by the Consultant in USA to the Indian investor. Further, applicant will arrange facilitate meetings between investors and the Consultant Manager and once the investors agree to invest, applicant will help them in all respects to complete the formalities in a perfect manner so that the applic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sec 13(2) of IGST Act, 2017 is reproduced below 13(2) The place of supply of services except the services specified in sub-sections (3) to (13) shall be the location of the recipient of services: Provided that where the location of the recipient of services is not available in the ordinary course of business, the place of supply shall be the location of the supplier of services. Section Extract Applicability? 13(3) (3) The place of supply of the following services shall be the location where the services are actually performed, namely: (a) services supplied in respect of goods......... Provided ................. (b) services supplied to an individual, .......... Applicant does not provide any of the services listed in the Section 13(4) The place of supply of services supplied directly in relation to an immovable property, .............. ---do--- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... classifiable under SAC 9961 / 9962 or any other heading? AND Question 4: Whether the Handholding services to be provided by the Applicant will be an export of services as defined under Section 2(6) of the Integrated Goods and Services Tax Act 2017? As discussed above the applicant is providing intermediary service in the name of hand holding service and not 'support service' as being claimed by the applicant and the said service does not qualify to be an export of service for the same reasons stated in the discussion under the Question 1 and 2 above. 05. In view of the extensive deliberations as held hereinabove, we pass an order as follows ORDER (Under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017) NO.GST-ARA- 103/2018-19/B-63 Mumbai, dt. 01/06/2019 For reasons as discussed in the body of the order, the questions are answered thus - Question 1) Whether the Marketing services to be supplied the Applicant under the Foreign Immigration Advisor to the Consultant Manager constitu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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