Goods Shed Services Taxable at 18% GST

By Centax

July 18, 2025

• 2 min. read

Case Details: In re: FLY ASH MOVERS INDIA Pvt. Ltd. (2025) 32 Centax 193 (A.A.R.-GST-Mah.)

Judiciary and Counsel Details

Ms Priya Jadhav, Member (Central Tax) & Shri D.P. Gojamgunde, Members (State Tax)

Facts of the Case

The appellant was awarded a contract for the development, reconstruction, maintenance, housekeeping, and security of the Kalamboli Goods Shed as a common user facility through private investment, in lieu of a share in Terminal Charges and Terminal Access Charges, for a period of ten years. The appellant was required to maintain both the existing and newly developed infrastructure at its own cost and was also responsible for the security of the facility. The consideration for the work consisted of ninety percent share in the Terminal Charges and Terminal Access Charges for all inward and outward traffic handled at the Kalamboli Goods Shed for ten years from the date of completion of the work. In addition, the appellant was granted a license to erect hoardings for advertisement and to operate a catering stall on the premises. The agreement provided that the common user traffic facility developed by the appellant would become the property of the railway administration, with no claim by the licensee on such assets. The issue for determination was whether the services provided constituted a composite supply or a mixed supply and the applicable classification and tax rate, and the matter was accordingly placed before the Authority for Advance Ruling (AAR), Maharashtra.

AAR Held

The Maharashtra AAR held that the services provided by the appellant comprising reconstruction, maintenance, housekeeping, and security of the Kalamboli Goods Shed to the Central Railway did not qualify as a composite supply of service but constituted a mixed supply of service. The AAR observed that the appellant was providing a combination of works contract services, maintenance, housekeeping, and security services to the Central Railway and such services could not be treated as transportation of goods by rail. It was further held that the supply of mixed services with works contract relating to repairs and maintenance being the component attracting the highest rate of tax at eighteen percent would be classifiable under Heading No. 995419 (repairs and maintenance). The AAR concluded that the services provided by the appellant were appropriately classifiable under Heading No. 995419 and chargeable to tax at the rate of eighteen percent in terms of Section 8 of the CGST Act and Maharashtra GST Act.