GST on Vouchers Limited to Commission – Not Turnover

Centax Editorial Board

April 28, 2026

• 2 min. read

Case Details: Neha Piyush Shah vs. Union of India (2026) 41 Centax 299 (Bom.)

Judiciary and Counsel Details

G. S. Kulkarni & Aarti Sathe, JJ.
S/Shri Prakash Shah, Sr. Adv., Saurabh Godbole & Sahil Mahajan, for the Petitioner.
Shri Karan Adik, for the Respondent.

Facts of the Case

The petitioner was engaged in the business of dealing with vouchers. A demand was raised under Section 73 of the CGST Act on the basis that sale and purchase of vouchers fell within the scope of supply and that the petitioner was dealing in goods. The adjudicating authority confirmed the demand by taxing the petitioner’s entire turnover, based on mismatch between the profit and loss account and GST returns. The petitioner contended that sale and purchase of vouchers did not constitute supply of goods or services and that only commission or fee earned in distribution or agency transactions was taxable in terms of Circular No. 243/37/2024-GST, dated 31-12-2024. The department rejected the petitioner’s contention for want of voucher sale and purchase ledgers and copies of invoices. The matter was placed before the High Court.

High Court Held

The High Court held that the observations in the order-in-original were not in consonance with Circular No. 243/37/2024-GST, dated 31-12-2024 and the existing legal position. The Court further held, prima facie, that where the petitioner was receiving commission in dealing with vouchers, only such commission or fees would be liable to GST and not the entire voucher turnover. It was also held that the demand raised on the full sale and purchase turnover was unsustainable on the material considered. Accordingly, the Court remanded the matter to the adjudicating authority for de novo consideration in accordance with law.