Stipend Disbursement and Item Sales at Cost Not Exempt as "Pure Agent" Services Under GST Rule 33

The AAR ruled that Logskim's stipend disbursement to trainees does not qualify as a "pure agent" service under Rule 33 of CGST Rules, as they merely act as a conduit without procuring supplies or making payments to third parties. The authority found that Logskim failed to meet key conditions of Rule 33, particularly clauses (i) and (iii). Similarly, the sale of uniforms, shoes, and insurance premiums to industry partners, even at cost without markup, is taxable since "reimbursement at actuals" alone doesn't establish pure agent status. The AAR concluded that both the stipend amounts received and passed to trainees and the sale of items to industry partners are chargeable to tax under CGST/TNGST Acts, 2017. .....

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