Classification of Supply — The Applicant has sought Advance Ruling on the following questions :

1. Whether the issue of Own Closed PPIs by the ‘Applicant’ to customers be treated as supply of goods or supply of services as defined under the provisions of the CGST / SGST Act 2017 and rules, notifications there on.

2. If yes, is the time of issue of Own Closed PPIs by the ‘Applicant’ to customers is the time of supply of goods or services warranting tax liability.

3. If yes, what is rate of taxes applicable for such supply of goods or services as the case may be.

4. If yes, whether the issue of PPIs by Third Party PPI Issuers subject to GST at the time of issue in their Hands.

5. Whether the amount received by the ‘Applicant’ from Third party PPI issuers subject to GST.

6. If No, GST collection at the time of sale of goods or services on redemption of PPIs i.e. own and from Third Party will be a sufficient compliance of the Provisions of the CGST Act.

7. What is the treatment of Discount (the difference between Face value and discounted value) in the hands of issuer of PPI in case of third party PPIs. Whether the ‘Applicant’ will be liable to pay GST on this difference Value.

8. The Own closed PPIs issued by the Applicant are ‘vouchers’ as defined under CGST/TNGST Act 2017 and are a supply of goods under CGST/TNGST Act 2017.

9. The time of supply of such gift vouchers / gift cards by the applicant to the customers shall be the date of issue of vouchers if the vouchers are specific to any particular goods specified against the voucher. If the gift vouchers/ gift cards are redeemable against any goods bought, the time of supply is the date of redemption of voucher.

10. In the case of paper based gift vouchers classifiable under CTH 4911 the applicable rate is 6% CGST as per Sl.No.132 of Schedule II of the Notification No.1/2017-C.T.(Rate) dated 28.06.2017 and 6% SGST as per Sl.No.132 of Schedule II of Notification Ms. No. II(2)/CTR/532(d-4)/2017 vide G.O. (Ms) No.62 dated 29.06.2017 as amended. In the case of gift cards classifiable under CTH 8523 the applicable rate is is 9% CGST as per Sl.No. 382 of Schedule III of the Notification No.1/2017-C.T.(Rate) dated 28.06.2017 and 9% SGST as per Sl.No.382 of Schedule III of Notification Ms. No.II(2)/CTR/532(d-4)/2017 vide G.O. (Ms) No.62 dated 29.06.2017.

11. The questions raised at Sl.No. 4, 5, 6 and 7 are not answered for the reason that the said questions are not admitted as this authority does not have jurisdiction. — Kalyan Jewellers India Limited, In Re… [2019] 18 TAXLOK.COM 103 (AAR-Tamil Nadu)