Notification no 12/2017 CTR gives exemption for service provided by GTA, by way of transport in goods carriage of -
(b) goods, where consideration charged for the transportation of goods on a consignment transported in a single carriage does not exceed one thousand five hundred rupees
(c) goods, where consideration charged for transportation of all such goods for a single consignee does not exceed rupees seven hundred and fifty ;
This kind of limit was there even during Service tax regime
GST payable on GTA service on Forward Mechanism Basis
Example for (b) as I understood and created
In a goods carriage,
consignor A booked for consignee B Freight ₹ 600,
consignor C booked for consignee D Freight ₹ 400
consignor E booked for consignee F Freight ₹ 600
Aggregate Amount (600+400+600)= Rs 1600
Answer
GST payable by GTA (Forward mechanism)
Reason
Consideration charged in a single carriage exceeded ₹ 1500
Example for (c) as I understood and created
In a goods carriage
Consignor A booked for consignee Z Freight ₹ 600,
Consignor B booked for consignee Z Freight ₹ 200,
Aggregate Amount (600+200)= ₹ 800
Answer
GST payable by GTA (Forward mechanism)
Reason
Consideration charged for transportation of all such goods for a single consignee exceeded ₹ 750
Finding out aggregate amount as mentioned above (Rs 1600 and ₹ 800) is possible only from the point of view of GTA on Forward charge mechanism basis, because this data is available only with GTA, not in the hand of consignor/consignee who is the receiver of service.
GST payable on GTA service on RCM basis
If the service receiver (take consignor A of eg above) is liable to pay GST on RCM basis, then in
Case (b)
Consignor A does not know how many other consignments are going in the truck in which his goods have been loaded. Due to non availability of such information, he has to pay, GST on RCM even though his bill (Rs 600) is below ₹ 1500.
Case (c)
Consignor A does not know whether any other consignors are sending goods to the same consignee (Z) in the truck in which he has loaded his goods. Due to non availability of such information, he has to pay, GST on RCM even though his bill (Rs 600) is below ₹ 750.
My view point
According to me this limit of ₹ 750/1500 as per the example have some sense only when we think from the view point of GTA who pays on FCM basis and not from the point of Service receiver who pays on RCM basis.
Then In such case every person whoever is paying freight charge to a GTA (even though it is Re1) has to take GST registration (Compulsory registration section 24 CGST) if they are liable to pay for GST on RCM basis due to non-availability of information as I quoted above.
My Question
Whether the example given above is correct? I got another example by another person in social media which is reproduced as follow. Is my example correct or the one reproduced is correct? According to me I am not able to connect the below example with the words used in exemption notification
Example Reproduced
If the GTA is carrying goods for a single consignee, then the exemption limit is 1500 per vehicle.
If the GTA is carrying goods for more than one consignee, then the exemption can be claimed by each consignee whose freight is upto Rs. 750 per consignment.
If what I have written above is totally wrong, experts please correct me.
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