Q 1- Whether amount recovered from the employees towards car parking charge payable to Shantiniketan properties private limited (building authorities), would be deemed as “Supply of Service” by the applicant to its employees?    
Ans:- The question is answered in affirmative.    
Q2- If the first question is answered in affirmative, whether the value of aforesaid supply would be NIL, being provided in the capacity of a “Pure Agent”? If valuation is not accepted as NIL, what would be the value of such supply?    
Ans:- Value of the Supply would be nil, subject to the fulfillment of the conditions prescribed for pure agent by the appellant.    
Q3- If GST is payable on the such amount recovered from the employees, whether the GST paid by the applicant to building authorities towards car parking charges would be admissible as input tax credit against supply of car parking services to employees?
Ans:- As the second question is answered in negative hence the question becomes redundant.

In view of the foregoing discussion and findings we hereby find that the Advance ruling Order No. 32 dated 30 June 2019, passed by the Authority on Advance Ruling is just and proper and no interference is required in the said ruling.
The appeal of the Appellant i.e. M/s Amar Food Products, 14/310,Madan Mohan gate, Agra is disposed accordingly.

In view of the foregoing discussion and findings we hereby modify the Ruling no. 17 dated 10-12-2018 of the Authority on Advance Ruling to the extent that-    
Goods under reference are classifiable under S. No. 13 of Schedule II of Notification 1/2017 Central Tax (Rate), vide Heading 0406  and taxable @ 12% GST (6% CGST+6%SGST). 

In view of the foregoing discussion and findings we hereby order as under:    
foregoing discussion and findings we hereby modify the ruling no. 06 dated 25-05-2018 of the Authority on advance ruling to the extent that-    
(i) Input Credit attributable to the supply of de-oiled rice bran cake (exempted supply) is to be reversed by the appellant in terms of Section 17(2) of the CGST Act 2017; and    
(ii) GST @ 5 is payable on supply of de-oiled mahua cake with consequently allowing the input credit in terms of Section 16 of the CGST Act 2017.    

In view of the foregoing discussion and findings we hereby modify the ruling no. 06 dated 25-05-2018 of the Authority on advance ruling to the extent that-    
(i) Input Credit attributable to the supply of de-oiled rice bran cake (exempted supply) is to be reversed by the appellant in terms of Section 17(2) of the CGST Act 2017; and    
(ii) GST @ 18% is payable on supply of de-oiled mahua cake with consequently allowing of input credit in terms of Section 16 of the CGST Act 2017.    

• The Member(SGST) has upheld the order of the AAR.
• The Member (CGST) has set aside the order of the AAR in favour of the Appellant.
• Therefore, as per Section 101(3) of the CGST Act, 2017 it shall be deemed that no advance Ruling can be issued in respect of the question under the Appeal.

Appeal by the party is rejected.
Supply of Branded Frozen Chicken packed by the appellant in individual LDPE bag in pre-determined quantities (one in number) and supplied to the Indian Army and Paramilitary forces in the HDPE bags as supply in Unit Container and not exempted under Entry No. 9 of the Notification No. 2/2017-CT (Rate), dated 28.06.2017 (as amended)