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1. Supervisory Charges are liable to GST| H & T
Contractor charges collected on actual basis is
not liable to GST

3. 1. Brief facts of the case:
1.M/s Karnataka State Warehousing Corporation (KSWC)
(“The Applicant”) is registered under GST in the state
of Karnataka. The applicant is a state government
undertaking owned by Central Warehousing Corporation
and Government of Karnataka in equal proportion.
2.Among various other services, The applicant is also
engaged in providing services of handling & transport,
loading & unloading of agricultural produce.
3.The Handling and transport work includes handling of
stock at the railhead, transportation to the
warehouses, unloading and proper stacking inside the
godowns, re-bagging, salvaging, standardization as may
be necessary and de-stacking and loading the same at
the time of delivery.
4.For the purpose of providing such service, the
applicant in turn obtains services Handling & Transport
(H&T) contractors.

4. Legal Extract:
1.Notification No. 12/2017-Central Tax (Rate) dated
28th June, 2017 contains list of services exempted
from GST. Entry No. 24(1)(e) is reiterated below:
• “…
• “
2.Storage and Warehousing service as explained by
CBEC in F.No.B11/1/2002-TRU, dated 01-08-20002, is
as follows:
• “Storage and Warehousing Service for all kinds of
goods are provided by public warehouses, private
warehouses, by agencies such as the Central
WareHousing Corporation, Airport Authorities,
Railways, Inland Container Depots, Container
Freight Stations, storage godown and tankers
operated by private individuals etc.”

5. Contention of the Applicant
1.As per Notification No. 12/2017-Central Tax (Rate)
under Entry No. 24 or SAC 9986, exemption is available
only with respect to loading, unloading, packing,
storage or warehousing of agricultural produce and not
in respect of supervisory charges.
2.Further, the supervisory charges are not covered in
definition of “storage and warehousing services” given
under explanation in CBEC in F.No. B11/1/2002-TRU,
dated 01-08-2020.
3.Therefore, Supervisory charges are covered under Entry
No. 998619 “Other support services to agriculture,
hunting, forestry and fishing” or under the SAC 996799
“Other supporting transport services n.e.c” or under
the SAC 999799 “Other services n.e.c” and therefore,
such charges would be liable to GST @9% CGST and 9%
KGST or 18% IGST