AAR Tamil Nadu rules that Flipkart’s proposed e-commerce-linked transportation services qualify as GTA and are exempt from GST for supplies to unregistered customers.
Saloni Kumari | Mar 23, 2026 |
AAR Tamil Nadu on Flipkart: E-Commerce Linked Transport Services Qualify as GTA with B2C Exemption
Flipkart India Private Limited (applicant) has filed an application in Form GST ARA-01 seeking the 411809, Goods and Services Tax (GST), Tamil Nadu, under Section 97 of the CGST Act, 2017, and corresponding provisions under Section 97 of the TNGST Act, 2017. The authority had received the application on June 16, 2025.
The applicant is located at Survey Nos 292-302, 126, and 295, Thiruvallur High Road, No. 111, Alamathi 2 Revenue Village, Sholavaram Panchayat Union, Tiruvallur – 600067.
The applicant is a private limited company incorporated under the Companies Act, 2013. Presently, the applicant is engaged in B2B trading of goods. The applicant is thinking of implementing a new model for its business (known as the “Proposed Model” in the advance ruling), under which the applicant would be providing transportation for the goods ordered through E-Commerce Operator (“ECO”) portals.
Questions Asked by AAR Tamil Nadu:
The following are the questions asked by the applicant seeking the AAR Tamil Nadu:
“Question 1: Whether the services provided by the applicant to customers would qualify as “Goods Transport Agency” (GTA) services?
Question 2: Whether the services provided by the applicant to unregistered customers through the Electronic Commerce Operator’s portal would be eligible for exemption in terms of Sl. No. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 (as amended)?”
Answers Given by AAR Tamil Nadu:
The following are the answers given by the AAR Tamil Nadu to the questions asked by the applicant:
Answer 1: Yes, the applicant’s service of transporting the goods ordered by customers using the e-commerce platform through the road qualifies for the “Goods Transport Agency” (GTA) category.
Answer 2: Yes, the services provided by the applicant to unregistered customers, who order goods using the Electronic Commerce Operator’s portal, are eligible for exemption under Serial No. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 (as amended).
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