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GST is not applicable for the services offered on MOU for a scheme to provide Subscription-based benefit for compensation in the event of death to the members of the Kudumbasree which is a State Government agency.

Levy of GST— In the instant case, the applicant is a Department of the Government of Kerala administering various insurance and other benefit schemes.

The applicant has requested an advance ruling on the following

Whether GST is applicable for the services offered on MOU for a scheme to provide 'Subscription-based benefit' for compensation in the event of death to the members of the 'Kudumbasree' which is State Government Agency.

The issue to be decided is the applicability of GST on the insurance services offered under an MoU for a subscription-based benefit for compensation in the event of death to the members of Kudumbasree a mission for poverty eradication and women empowerment of the Government of Kerala by the Department of Insurance of the Government of Kerala.

In the instant case, the service is provided by the applicant; a Department of the State Government, which is administering various insurance and other benefit schemes of the Government of Kerala.

On perusal of the MoU entered by the applicant with Kudumbasree, it is seen that Kudumbasree is collecting the annual subscription and paying to the applicant along with all the necessary information regarding the beneficiary /members and nominee in the specified format and in the event of death of the insured member the benefit is transferred to the member through Kudumbasree.

From the MoU it is evident that Kudumbasree is acting only as an agent for the collection of premium and disbursal of benefit to its members and the service is provided by the applicant to the members.

Hence the recipient of the services provided by the applicant is the individual members of Kudumbasree and accordingly the services are covered by the exemption under SI.No.6 of Notification No. 12/2017 Central Tax (Rate) dated 28.06.2017.

Held that—The applicant being a department of the State Government, the services provided under the MoU is exempted as per the entry at SI.No.6 of Notification No. 12/2017 Central Tax (Rate) dated 28.06.2017 for the reasons as discussed above.

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