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The ambit of Advance Ruling do not provide for answering the questions raised on provisions relating to ‘Tax Collected at Source’.

Authority for Advance Ruling – E-commerce operator The applicant is a platform aggregator of water and sewage tankers. They are engaged in helping clients book water tankers and sewage evacuation tankers for water supply and sewage services. The applicant sought an Advance Ruling as to whether supply of raw water falls under exempt goods under GST; the supplier of water through tankers comes under supply of raw water or under transport services; the applicant have to withhold any tax from the suppliers’ before making payments; is the supplier making raw water sale is required to register under GST since they are transacting through an e-commerce operator; does Sewage Evacuation come under 18% GST. The authority observed that advance ruling are decisions on questions specified in sub section 97(2) of the Act in relation to the supply of goods or services undertaken or proposed to be undertaken by the applicant. The applicant, who is an e-commerce operator, and not the ‘supplier’ of Raw water and Sewage Evacuation Services, the question raised on the classification of supply, applicability of Notification for such suppliers, is not the question on supplies being or proposed to be undertaken by him. Therefore, the questions raised do not pertain to the supply of the applicant and are not admissible for ruling.

Held that:- The Hon’ble Authority for Advance Ruling not admitted the application.

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