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TMI Blog2021 (2) TMI 198X X X X Extracts X X X X X X X X Extracts X X X X ..... supplies of goods or services or both, on the value determined under Section 15. Thus the value of the instant service need to be decided in terms of Section 15. Section 15 of the CGST Act 2017 deals with value of taxable supply and Section 15 (1) stipulates that the value of supply of goods or services or both shall be the transaction value, which is the price actually paid or payable for the said supply of goods or services or both where the supplier and the recipient of the supply are not related and the price is the sole consideration of the supply . In the instant case, the applicant (supplier) and the recipients are not related and the price is the sole consideration. Therefore the value of the taxable supply of manpower servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. Admissibility of the application : The applicant, filed the instant application, in relation to valuation of the manpower services. Further the applicant has sought advance ruling in respect of the question on the issues covered under Section 97 (2) (c) of the CGST Act 2017 and hence the application is admitted. 4. FACTS OF THE CASE 4.1 The applicant company, registered under provisions of the GST Act, engaged in providing manpower supply services based on requirement of the customers and contracts awarded. The applicant submitted that they had been awarded contract for supply of manpower, on acceptance of their tender by Karnataka State Rural Development and Panchayat Raj University, Gadag, Karnataka and consequently t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons under the KGST Act. 6.2 We have considered the submissions made by the Applicant in their application for advance ruling as well as the submissions made by Sri. Shivaraj Kumar, Director of the applicant company during the personal hearing. We have also considered the issues involved, on which advance ruling is sought by the applicant, and relevant facts. 6.3 The applicant sought the advance ruling on the valuation of the manpower services being provided by them to their customers supra. The applicant is being paid services charges @2%, in addition to the wages and hence they directed the applicant to charge GST on the service charges only but not on the bill amount. We proceed to examine the valuation of the manpower services. We ..... X X X X Extracts X X X X X X X X Extracts X X X X
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