Levy of GST— The present appeal has been filed against the Advance Ruling pronounced by the Maharashtra Authority for Advance Ruling.

In advance ruling order, it has been held that the activities undertaken by the Appellant will tantamount to those of "intermediary" as provided under Section 2(13) of the IGST Act, 2017 for the reason that the Appellant are arranging and facilitating the supply of goods or services or both between the Indian businesses and the Dubai businesses by connecting them by way of introductions/references, and thereby, it has been held that the impugned covered under the ambit of Supply" as provided under Section 7 of the CGST Act, 2017, and accordingly, the Appellant are required to take GST registration and discharge their GST liability on the amount received from their Dubai Head Office for undertaking the impugned activities at the behest of their Head Office. 

The moot issues before this authority are as under: 

(i) Whether the host of activities undertaken by the Appellant at the behest of their Dubai Head Office can be construed as that of an "intermediary" as held by the MAAR or otherwise;

(ii) Whether the said activities undertaken by the Appellant can be construed as "Supply" as envisaged under Section 7 of the CGST Act, 2017;

(iii) Whether the place of Supply of the impugned activities is within taxable territory; 

Held that— This authority modify the Ruling passed by the MAAR, by holding that the host of activities performed by the Appellant at the behest of their Dubai Head Office will come under the ambit of “Supply" in terms of Section 7(1)(a) of the CGST Act, 2017, and are required to take GST registration, and discharge their IGST liability, if any, on the amount received from their Dubai Head Office.