Home Delivery Services By E-Commerce Platforms To Consumers Exempt From GST: West Bengal AAR

Flipkart India Private Limited, which was already engaged in B2B trading of goods, proposed to introduce a logistics model involving transportation of goods exclusively by road for customers purchasing goods through an e-commerce platform operated by Flipkart Internet Private Limited. At the time of filing the application, the proposed activity had not commenced and the ruling was sought strictly in respect of the proposed model.

Under the proposed arrangement, sellers listed on the e-commerce platform would deliver goods only up to a designated Source Mother Hub, being the nearest logistics hub from the seller's location. From this point, the applicant would undertake transportation of goods to the delivery address of the end customer.

The movement could involve multiple transit points such as Source Mother Hub, Destination Mother Hub, and Delivery Hub before reaching the customer, but the entire transportation would be carried out exclusively by road using trucks, vans, two-wheelers, or a combination thereof.

The applicant would issue a single consignment note covering the entire journey from the Source Mother Hub to the end customer's address. Transportation could be undertaken either by the applicant itself or through third-party transporters. The applicant would not own the goods at any stage, as ownership and title would pass directly from the seller to the buyer in terms of the Buyer's Terms of Use on the e-commerce platform. The applicant's role was confined strictly to providing logistics and delivery services.

A separate contractual arrangement existed between the applicant and the end customer under the Buyer's Terms of Use. By placing an order on the platform, the customer agreed to engage a transporter, facilitated by the e-commerce operator, for movement of goods at the customer's own account.

Transportation charges were payable by the end customer, either online through the portal or on a cash-on-delivery basis, and were separately reflected in the invoice or bill of supply issued by the applicant. The applicant also proposed to arrange transit insurance for the goods during transportation.

On these facts, the applicant sought an advance ruling on whether the proposed services qualified as GTA services and whether GTA services provided to unregistered customers through an e-commerce platform were exempt from GST.

The Authority held that the proposed activity squarely qualified as GTA services, noting that the statutory definition requires transportation of goods by road and issuance of a consignment note, both of which were satisfied. It was observed that issuance of a consignment note is a sine qua non for classification as a GTA, as it shows transfer of lien over the goods and responsibility for safe delivery.

The Authority relied on principles evolved under the erstwhile Service Tax regime and clarified that ancillary and incidental activities such as loading, unloading, transshipment, and temporary warehousing, when provided in the course of transportation, form part of a composite supply of GTA services in terms of CBIC Circular No. 234/28/2024-GST dated 11.10.2024. It was also held that the applicant's activity could not be equated with that of a courier agency since transportation was entirely by road and supported by issuance of a consignment note.

On the question of exemption, the Authority noted that the end customer is the recipient of the transportation service within the meaning of Section 2(93) of the CGST Act, as the consideration for transportation is borne by the customer. Where such end customers are unregistered persons, the GTA services provided by the applicant fall within the scope of Serial No. 21A of Notification No. 12/2017–Central Tax (Rate).

The Authority concluded that GTA services provided to unregistered individuals, who do not fall under the excluded categories specified in the said entry, are fully exempt from GST, and that incidental and ancillary services provided in the course of such transportation would also enjoy the same exemption as part of a composite supply.

Case Name: In Re: Flipkart India Private Limited

Ruling Date: 09 December 2025

For Applicant: Mr. Rohit Jain and Mr. Supreme Kothari