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Mere renting of space cannot be said to be in the nature of service provided for storage or warehousing of goods, the amount of rent paid by the Appellant is taxable under the category 'Rental or leasing services involving own or leased non-residential property'

Classification of service— In the instant case, the Appellant has entered into an agreement with Central Warehousing Corporation (CWC) for use of storage space for storage of Public Distribution System commodities belonging to the Appellant.

We find that this is an appeal filed by the Appellant as a recipient of the service rendered by CWC. They had sought an advance ruling on the applicability of GST on the service provided to them by CWC in terms of the authorisation agreement.

The issue in appeal is whether the service rendered by CWC to the Appellant is exempted in terms of entry Sl. Nos 54 or 24 of Rate Notification No 12/2017 CT (R) dated 28-06-2017. It is the contention of the Appellant that the service provided by CWC is the storage of agricultural produce. On the other hand, the lower Authority has held that the service provided by CWC is renting of immovable property.

held that— we agree with the findings of the lower Authority and hold that the service supplied by CWC to the Appellant is renting of immovable property.—Karnataka Food & Civil Supplies Corporation, In Re… [2020] 21 TAXLOK.COM 154 (AAAR-Karnataka)

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