The Authority for Advance Rulings (AAR), Telangana in the case of M/S. DRS DILIP ROADLINES LIMITED vide A. R. Com/03/2024, TSAAR Order No. 07/2024 dated 26.04.2024, has held that services such as packing, loading, unloading, and unpacking would fall under the purview of a Goods Transport Agency if they are directly linked to the transportation of the same goods.

Facts of the Case:- In this case, the applicant works as a Goods Transport Agency (GTA). They have submitted that transportation of goods is their main activity and packing, loading, unloading & unpacking are ancillary to their main activity and that their clients prefer their services as they provide all the above services. Further, it was submitted that they have opted for Forward Charge Mechanism (FCM).

Issue:- Whether the supply of services including transportation, packing, loading, unloading & unpacking forms a single bundled supply, and whether the principal supply in this transaction is transportation.

AAR's Rulings:-  The AAR has ruled as under:-

• The Entry No. 9(iii) of Notification No. 11/2017-CT(R), Dt. 28-06-2017 enumerates ‘Services in relation’ to transport of goods by road. Thus all services rendered in relation to transportation of goods including packing, loading, unloading & unpacking fall under this entry provided that such services have a direct and immediate link with the covanent/agreement for transport of goods i.e., the contract shall be for transport, packing , loading, unloading and unpacking of the same goods.
• Therefore, if the transactions made by the applicant are in substance contracts for transport, packing, loading, unloading of the same goods entrusted by their customers, then such services fall under Entry 9(iii) of notification 11/2017-CT (R) dt. 28-06-2017 i.e., goods transport Agency.