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April 2, 2022

Transportation Of Parcels By GSRTC In Its Buses Attracts 18% GST

by CA Shivam Jaiswal in GST, Legal Court Judgement

Transportation Of Parcels By GSRTC In Its Buses Attracts 18% GST

Fact and Issue of the case

M/s. Gujarat State Road Transport Corporation (hereinafter referred to as GSRTC for the sake of brevity) submits as follows:

GSRTC operates more than 8700 buses daily basis and is engaged in intra state as well as interstate passenger transportation

GSRTC submits that it is mainly engaged in the passenger transportation services

GSRTC entered agreement with M/s Ashapura Trade and Transport Private to provided space in its buses, on top of the bus as well as in bus cabin, for transporting parcels of Ashapura. The parcels booked by Ashapura and transported by the buses run by GSRTC from one station to another station which comes in its scheduled route. GSRTC submits that it is not issuing any consignment note, nor is engaged in door to door delivery of the parcels booked by Ashapura. For the transportation of said parcels, GSRTC receives consideration as per the agreement.

Observation of the Court

Court has carefully considered the submissions made by GSRTC.

On reading of the Agreement entered by GSRTC with Ashapura, court finds that said agreement expired on 30-6-20. Shri Thakkar during the personal hearing, submitted that GSRTC intends to do such activities, as detailed in agreement submitted before us, in future. GSRTC vide its letter dated 18-2-22 submitted that it intends to carry on such activities on the same terms and condition ( as per submitted agreement) in future and in anticipation of the same, GSTRC filed the present application before us. Court, thereby,  holds that GSRTC has locus standi, as per Section 95(a) to seek Ruling on its proposed supplies to be undertaken by it and thus the subject Advance Ruling Application is admitted taking into account GSRTC’s letter dated 18-2-22.

Court finds that GSRTC provides services to such firms/ agencies (its service recipients) carrying on the business of transportation of parcels, specific allied services. Court agrees with GSRTC that it itself is not a courier agency as it is not engaged in door to door transportation of goods/articles/documents. It is a fact on record that Ashapura is engaged in door to door transportation of its parcel goods but not GSRTC.  What  Court finds from the agreement is that GSRTC’s services to Ashapura is supporting the business of Ashapura, by transporting the parcels of Ashapura from one destination to other, wherein Ashapura is both the consignor and consignee at the respective bus stations. Ashapura utilises the services of GSRTC for enabling it ( Ashapura) for door to door delivery of parcels. Further, the specific activity of GSRTC supplying parcel office space/cabin/shed to Ashapura falls under the category of infrastructural support services which is a subset of Business Support Services. Court holds GSRTC supplies Business Support Services to its service recipient. The standard agreement submitted before us asserts our findings.

Courts find that GSRTC is not a Courier Agency as it is not involved in door to door transportation of goods/articles/documents.

Though GSRTC transports goods by road in its buses and issues parcel receipt, Court is  not inclined to accord this activity of GSRTC to fall under goods transport agency service for the following reasons

i.   The service description in subject matter is Business Support Service and GSRTC supports the services to be supplied by Ashapura to its (Ashapura’s) recipients.

ii.  GSRTC in the said agreement at para 7(q) submits that it is not responsible or liable in case the parcels, courier covers is lost or damaged in transit, in the buses or premises or bus stations, recipient shall be solely responsible and liable for the same.

What Court finds is that although a parcel receipt is issued by GSRTC, it absolves itself from any responsibility of the parcels after receipt. Thus Court finds it hard to equate this parcel receipt to a consignment note wherein the responsibility of the goods being transported is not on the consignee.

iii. Further, the consideration received by GSRTC includes the following:

a.  Charges for transportation of parcel

b.  Charges for providing parcel office space.

In continuum to holding that GSRTC is not supplying goods transport agency service, We also concur with GSRTC that its services will not be classified as supporting services for road transport under SAC 99674.

In conspectus of aforementioned discussion and findings, Court passed the Ruling.


1.  In this specific scenario presented before us, GSRTC supplies Business Support Service to its recipient.

2.  SAC is 998599, covering Other Support Services n.e.c.; GST rate being 18%.

3.  GSRTC is neither a GTA nor a courier agency, thus the Ruling with respect to Question (b) & (e) is thereby not applicable, in view of aforementioned Ruling at Sr. No. 1.


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