“Commission” received in convertible foreign exchange for rendering services as an “Intermediary” from overseas is an “export of services”

THE AUTHORITY OF ADVANCE RULING

The Question and Ruling as follows:

Whether the “Commission” received by the Applicant in the convertible foreign exchange for rendering services as an “Intermediary” from overseas clients, on account of….

a. Trade in goods between an exporter abroad receiving such services and an Indian importer of goods, is an “export of services” falling under Section 2(6) & outside the purview of Section 13(8) (b), attracting zero-rated tax under Section 16 (1) (a) of the Integrated Goods and Services Tax Act, 2017?

b. If the answer to the question above is in the negative, whether the impugned supply of service forming as integral part of the cross-border sales/purchase of goods, will be treated as an “intra -state supply” under Section 8(1) of the IGST Act read with Section 2(65) of the MGST Act. Attracting CGST/MGST? And at what rate?

RULING

The subject applicantion filed for advance ruling is rejected, as being non-maintainable as per the provisions of the GST Act, 2017 and Rules made thereunder.