Concept Of Supply Under GST

Part-I:
This part will only cover the explanation of the inclusive meaning of the word “supply” under the GST Law. The remaining aspects will be discussed in subsequent parts.
With the introduction of GST Laws, there has been a paradigm shift in the Indirect Taxation structure in India. In the Pre-GST era that is prior to 01/07/2017, Indirect Taxes were under separate heads and with distinct identifiable taxable events. However the process of subsuming of taxes has led to existence of one single tax namely “The Goods and Services Tax” with a single identifiable taxable event called “Supply”. It sounds so simple that there is only a single taxable event, however on exploring the actual scope, one can understand that it may a single event, but has multiple dimensions covered under its gamut.

Taxable event means that particular instance or action which creates the incidence of tax. The levy of tax is on the happening of taxable event, thus for the levy of GST, there has to be an activity taking place called as “Supply”. The Supply may be of Goods or Services or both. So what all exactly falls in under the purview of the word Supply, here is an analysis.

Section 7 of the CGST Act 2017,
For the purposes of this Act, the expression “supply” includes–– (a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange, license, rental, lease or disposal made or agreed to be made for a consideration by a person in the course or furtherance of business;
(b )Import of services for a consideration whether or not in the course or furtherance of business; and
(c) The activities specified in Schedule I, made or agreed to be made without a consideration;
(1A) where certain activities or transactions constitute a supply in accordance with the provisions of sub-section (1), they shall be treated either as supply of goods or supply of services as referred to in Schedule II.
(2) Notwithstanding anything contained in sub-section (1),–– (a) activities or transactions specified in Schedule III; or (b) such activities or transactions undertaken by the Central Government, a State Government or any local authority in which they are engaged as public authorities, as may be notified by the Government on the recommendations of the Council, shall be treated neither as a supply of goods nor a supply of services.
(3) Subject to the provisions of sub-sections (1) (1A) and (2), the Government may, on the recommendations of the Council, specify, by notification, the transactions that are to be treated as— (a) a supply of goods and not as a supply of services; or (b) a supply of services and not as a supply of goods.

Section 7 had undergone changes vide the CGST Amendment Act 2018, effective from 1/02/2019, the same have been envisaged in the text above.
Analysis of the Legal Provision:
Part I: (Supply includes [a]……. furtherance of business): The meaning of the word “supply” given is by way of an inclusive definition

Supply of goods or services or both by way of sale, transfer, barter, exchange, license, rental, lease or disposal Made or agreed to be made For a consideration (Exception Schedule I) In the course or furtherance of business.

As defined u/s 2(52) of the CGST Act 2017, Goods means every kind of movable property other than money and securities but includes actionable claim, growing crops, grass and things attached to or forming part of the land which are agreed to be severed before supply or under a contract of supply.

As defined u/s 2(102) of the CGST Act 2017, Services means anything other than goods, money and securities but includes activities relating to the use of money or its conversion by cash or by any other mode, from one form, currency or denomination, to another form, currency or denomination for which a separate consideration is charged.

Sale and Transfer: The terms Sale and Transfer have not been defined under the CGST Act 2017.
Referring to the provisions of Sale of Goods Act, Indian Contract Act and the meanings envisaged in the VAT/CST Laws, the term “sale of goods/transfer” can be understood as to a change in ownership of goods, whereby there is a transfer of risk and rewards in the goods. In this case the possession may or may not be transferred. Thus sale of goods amounts to “supply”.
Eg: Goods lying in “A’s” warehouse, sold to “B”. “B” will however further sell such goods from “A’s” warehouse only. In such case, there is sale of goods, even the risk and reward gets transferred, and however, the possession of the goods does not change.

In case of services, it is referred to as “provision of services” or “rendering of services”, thus the provision/rendering of services, makes the recipient endure the benefits of services against a consideration paid to the supplier of service. Such provision/rendering of service will amount to “supply”.
Eg: A Chartered Accountant provides project feasibility study services to a Builder for a fees of Rs 1,00,000. In such case there would be a provision of professional services to the builder for a consideration. It will amount to supply of service.

Barter and Exchange:
In the ancient days, when currency was yet to be recognized, barter system was used in order to facilitate trade. Thus this terminology has an economic history attached to it. Usually the barter use to take place between the commodities which were believed to have the equal values. This concept was only known in case of exchange of “Goods”, as “Service” market per-se did not exist then. However, as envisaged under the GST Law, the term Barter may also be in case of Services. Let us understand how the term “Barter” is relevant under the GST Law.
Eg: A Chartered Accountant provides Audit services to an entity engaged in selling “Printing and Stationery”. In return he asks the client entity to supply all the printing and stationery required for his office, for the year. The Chartered Accountant does not charge any fees and so also his client does not charge anything for the supply of “Printing and Stationery”. In the given case, the Chartered Accountant would not charge fees, so also the supplier of “Printing and Stationery” will not charge anything for the supplies. Let us assume the value of service provided and the printing stationery received in return is Rs 50,000 per annum. In this case, there is a value creation of Rs 1,00,000 (50,000 by Chartered Accountant and Rs 50,000 by the supplier of Printing and Stationery). If the same is not tapped under the levy of GST, then it would lead to a loss of tax on total value created Rs 1,00,000. However now since Barter is a supply (taxable event), even though actually there is no give and take of the consideration amount, GST would be leviable on the entire transaction. Thus a potential revenue leakage on the front of tax collection for the government can be avoided.

Exchange: As far as exchange is concerned, it is also a concept similar to Barter. There is however a thin line of difference, in exchange the value of goods/services exchanged for, may not be assumed to be same or will not be of same value. In case of “Exchange” the difference in values of goods/services, is generally settled by way of monetary consideration.
Eg: Mr X a TV shop owner is willing to buy stock of new TV’s worth Rs 40,000 each, from the manufacturer. The TV manufacturer offers to buy old unsold stock of TV’s in exchange of the new one. Mr X gives his old TV, which is valued at Rs 7,000 and settles the differential consideration for Rs 33,000. In this case, there is a value creation of Rs 40,000 by the manufacturer and there is a value creation of Rs 7000 by Mr X. However if the net consideration is given an effect, then GST will be levied only on Rs 33,000. Therefore in this case, the GST would be leviable on Rs 40,000 by the manufacturer and on Rs 7000 by
Mr X.
Thus, it can be understood that, in case of Barter and/or Exchange transactions, there is a possibility of huge tax revenue leakage. Thus it can be said that the same has been aptly brought under the taxation net.

License, Rental, Lease: Any transfer of right to use goods or right to use immovable properties is envisaged under the ambit of License, Rental or Lease. Specifically the common aspect is there is a transfer of rights to enjoy the possession of any goods or to enjoy the possession of immovable property for a consideration would be considered as a supply. Although the terms “License”, “Rental” and “Lease” sound interchangeable, there is minute difference amongst them.
Eg: Leasing of a warehouse for 5 years.
Eg: Renting of Plant and Machinery.
Eg: Licensing agreement to use a copyright or trademark.
In the above cases, under various instances the transactions amount’s to supply.

Dispoal: Any disposal of business asset, for a consideration. In such case the disposal may relate to any business assets. It may be inventory or a fixed asset. Disposal means removing the asset from the business books for any reason be it a sale, write off. However if the consideration (Exception under Schedule I) is absent, there would not be any supply. There are certain exceptions also under Section 17(5), where disposal by way of gift/samples leads to blocked credits (The same is discussed under the Input Tax credits section).

Concept of Supply Part II
In this part, we shall discuss the clause (b) and clause (c) of Section 7 of the CGST Act 2017

Section 7, (For the purpose of this section, supply includes………As per clause (b ) of Section 7 of the CGST Act 2017 , Import of services for a consideration whether or not in the course or furtherance of business.

The term Import of services has been defined in Section2 (11) of the IGST Act 2017, “import of services” means the supply of any service, where
(i) the supplier of service is located outside India.
(ii) the recipient of service is located in India.
(iii) the place of supply of service is in India.

It would be pertinent to note that for a transaction to be an “Import of service”, it must fulfill all the above requisites. Another factor to be considered is that an import of service is considered as a supply if the same is being made for a “Consideration”. However it is immaterial, if the import of service has been made in course or furtherance of business.

Illustration 1:
X Ltd India imports technological support services from YB inc USA, for its business. X Ltd has also duly paid consideration for technological support services. This amounts to a supply under GST Laws. GST would be payable in this case under the Reverse Charge Mechanism by virtue of notification 13/2017 Central Tax, issued under the provisions of Section 9(3) of the CGST Act 2017.
Illustration 2:
Mr X in India has purchased a subscription for a fitness Application on his mobile phone for his personal usage for an amount of Rs 3,500. The mobile application owner/developer is located in UK. Considering the definition of Import of service as mentioned above, it can be said that there is “Import of Service” taking place for a consideration. Even though the service is not to be used in course or furtherance of business, still the import of service for consideration would amount to supply. In such case assuming that Mr X is not registered, the UK based app owner/developer would be required to have a representative in India for paying GST on his behalf. The issue is that GST under reverse charge cannot be paid in a B to C transaction.

As per clause (c) of Section 7 of the CGST Act 2017, Activities specified in Schedule I to the CGST Act 2017, which are made or agreed to be made without consideration also amount to supply.
Permanent transfer or disposal of business assets where input tax credit has been availed on such assets
Any activity of permanent transfer of business asset (fixed asset /inventory), on which Input tax credit is availed, on account of scrapping of assets on being obsolete or even distribution as a sample, where absolutely no consideration is recovered. In such case, the transaction amounts to “supply” even if it has been undertaken without consideration. It would be important to note that in such case there would be no GST payable on outward supply as the consideration is absent (assuming that such transfer or disposal is being made to a unrelated person) where the transaction value is NIL. However the Input tax credit availed if any will have to be reversed. In disposal of business asset without consideration to a related person, even though the transaction would be without consideration, the valuation as “transaction value” will not be acceptable and thus valuation of outward supply will be determined using the CGST Valuation Rules.
Supply of goods or services or both between related persons or between distinct persons as specified in section 25, when made in the course or furtherance of business. Provided that gifts not exceeding fifty thousand rupees in value in a financial year by an employer to an employee shall not be treated as supply of goods or services or both.
Since the Pre-GST regime, the transactions between related persons have always been under the scanner. The obvious reason is that there is always a high probability of value manipulation which the related parties can undertake for mutual benefits also leading to evasion of tax. Thus the specific provision under this schedule envisages the scenario of “Zero consideration” transactions amongst the “Related Persons”, which has been considered as a “Deemed Supply”, and thus GST would be payable. The value in such case will have to be determined as per the CGST Valuation Rules.

Distinct person is a new concept which has been introduced under the GST Laws. Since the registration under GST is recognized qua the state, a person having same Permanent Account Number (PAN), if has registered business across various states/Union territories, then his registration in one state would be considered as a distinct person for another. In the Pre-GST regime, often a transaction of “Stock Transfer” would be undertaken. A person use to send his goods one branch to another branch in different state/union territories. Under the Pre-GST regime this transaction would amount to mere “Stock transfer” which did not attract any output tax. Only implication would be in respect of “Tax retention”. However the same does not happen under the GST regime. A mere transfer of stock from one branch to another branch in a different state/union territory would amount to supply, even if the same is without consideration. In such case Outward GST is payable and the valuation for the purpose of determining “GST liability” will have to be done according to
the CGST Valuation Rules.

“Employees” have also been encapsulated as a part of the term “Related persons”. Thus supplies made to employees by the employer, especially “free of cost” have also come under the lens of the tax authorities. Gifts to employees is not a unusual in the business scenario. Thus the provisions clearly mentions that “gifts to employees up to a value of Rs 50,000 per annum, would not be considered as a supply. However any gifts given in excess of Rs ,50,000 per employee would amount to “Supply” under this act and would be liable to tax.
Illustration: If an employer has procured refrigerator worth Rs 25,000, and given it as a gift to the employee, then such gift would not amount to “Supply” as the value per annum is less than Rs 50,000. However if the price of the refrigerator is Rs 52,000, then gifting such fridge would amount to supply, and GST would be payable on Rs 52,000 and not just on amount over and above Rs 50,000.

Supply of goods a) by a principal to his agent where the agent undertakes to supply such goods on behalf of the principal; or (b) by an agent to his principal where the agent undertakes to receive such goods on behalf of the principal.
Supply of goods through agents was not under the taxation net under the Pre-GST regime, as there was no sale made in such case, rather the agents would be only given the possession of the goods with a responsibility to sell the same. However with the introduction of the GST Laws, the supplies made to agents by the principal or supply made by the agent to the principal where he has received goods on behalf of the principal, would be a taxable event under the GST Laws, and the tax would be payable. In this case generally the agents are to receive consideration in form of commission. That is to say the agents do
not receive or pay anything for the goods they procure or receive on behalf of principal.
However the supply of goods to agents would attract GST. The valuation of goods supplied, for the purpose of determining GST will be done as per the CGST Valuation Rules.

Import of services by a taxable person from a related person or from any of his other establishments outside India, in the course or furtherance of business.
Import of services by any person for a consideration is considered as supply even if the same is used in the course or furtherance of business. However import of services by a taxable person from a overseas related person or from his own establishment outside India, will be considered as a supply even if the same is without consideration. In such case it would be pertinent to note that the valuation of transaction would be done as per the CGST
Valuation Rules.

Concept of Supply Part III
In this last part of the series “Concept of Supply”, we shall discuss the Schedule II and III to the CGST Act 2017
[ ………..(1A) where certain activities or transactions constitute a supply in accordance with the provisions of sub-section (1), they shall be treated either as supply of goods or supply of services as referred to in Schedule II……….]
Section 7 of the CGST Act 2017, was amended with effect from 1/2/2019. The amendment led to the insertion of the aforementioned sub section (1A) to section 7. As a reason of the amendment, it has been clarified that, Schedule-II to the CGST Act 2017, do not possess the ability to conclude if any activities amount a “supply”. Whereas if any activity amounts to “Supply” as per Section 7(1), “Schedule-II will only identify as to what is to be considered as “supply of goods” or “supply of services”. The introduction of this schedule under the GST Laws, puts to rest the long drawn litigations, which existed in contracts wherein “goods and or services or a combination of both existed” during the pre GST regime.

Schedule II: “Activities” or “Transactions” to be treated as “Supply of Goods” or “Supply of Services”.

1. Transfer:
   (a) Any transfer of the title in goods is a supply of goods
   Any activity which would result in change in the title of goods will be regarded as “supply of goods”. The terms of consideration may be immediate or deferred, as long as the seller is transferring the “risk” and “rewards” in the goods, it would be considered as a “supply of goods”.
   Eg: Sale of 100 chairs by a carpenter, 50% being paid immediately and 50% to be paid in 60 days. In such case the change in title of goods is immediate, even though the payment terms are as mentioned. Thus this transfer is considered purely as “supply of goods”(benches).
   (b) Any transfer of right in goods or of undivided share in goods without the transfer of title thereof, is a supply of services.
   Where the essence of any contract entails retaining the ownership of goods with the actual owner, however the right to enjoy the possession is transferred, such contracts would be considered as “supply of services”. The tenure of transfer of possession may differ from case to
   case basis; however the nature of supply would continue to remain as “supply of services”.
   Eg: In the example given above, If the carpenter has agreed to give 100 chairs on rent instead of selling them, and the possession can be enjoyed by the recipient for an agreed period of 3 years. In such case the possession would be transferred immediately against rent to be received and this “transfer of possession” would be treated as “supply of services”.
   (c) Any transfer of title in goods under an agreement which stipulates that property in goods shall pass at a future date upon payment of full consideration as agreed, is a supply of goods. Goods which are sold under financing models such as “Hire purchase” or “Lease”, wherein the ownership is not immediately transferred but is agreed to be transferred in future. In case of such transaction, although the ownership is not transferred immediately but is agreed to be transferred, for the purpose of GST Laws, such transfer is considered as “supply of goods”.
   A clear distinction between supply as “goods” or “services” helps to a concrete treatment from the tax perspective and also, the rate of tax can be accordingly determined.
2. Land and Building
   (a) any lease, tenancy, easement, licence to occupy land is a supply of services
   Where there is an agreement through which only the “right to occupy land “is given but not the “right to own the land”, it may can be said to be a “supply of services”.
   Eg: A land owner has entered into an agreement to allow usage of his land by a company for setting up and running “circus” shows for a period of 2 months. It will be purely considered as a supply of services.
   (b) any lease or letting out of the building including a commercial, industrial or residential complex for business or commerce, either wholly or partly, is a supply of services.
   Eg: In case of contract of renting of a office space, which only provides “rights to occupy the office space” for the agreed time against payment of rent, but does not give “right to own the office space”. Such contract is considered as a “supply of services”.
   Eg: In case of a residential premises is let out, for use as an office, in such case, it would constitute as supply, and would be liable for GST, although it will also be considered as a “supply of services”.
3. Treatment or process
   Any treatment or process which is applied to another person’s goods is a supply of services. Contracts under which, goods belonging to other person are subjected to treatment or process, and where the owner of the goods pays a consideration in respect of carrying out such treatment or process, will be considered as a supply. In such case the effective position of the goods is with the person who carries out such treatment or process, however the ownership of the goods continues to remain with the owner of goods. Such a transaction is considered as a “supply of service”.
   Eg: “Zen Trucks” is a manufacturer of trucks and offers various types of carrier bodies for its buyers. The trucks can be sold as a “goods carriage van” or “cold storage van” etc. Based on the orders placed by the buyer, “Zen Trucks” gives the “treatment” or “process” orders to M/s “Well build” a company engaged in “Body Building and Designing”. In such case the trucks on its basic frame (CHASIS), are sent by “Zen Trucks” to M/s “Well Build”. M/s “Well Build” is only responsible to carry out the desired type of “Body Building & Designing”. They will be paid consideration for carrying out such “process”. The ownership of the trucks always is with “Zen Trucks”. Thus this transaction of carrying out the “process” on goods belonging to others, is considered as a “supply of services”.
4. Transfer of business assets
   (a) Where goods forming part of the assets of a business are transferred or disposed of by or under the directions of the person carrying on the business so as no longer to form part of those assets, whether or not for a consideration, such transfer or disposal is a supply of goods by the person
   In a usual business scenario there can be a possibility of stock “write off” or “disposal of stock” on being obsolete or owing to a business decision. In such a situation even if such disposal takes place with or without consideration, it will tantamount to “supply”. Such supply would be considered as “supply of goods”. The liability of GST can be in the following manner.

(b) where, by or under the direction of a person carrying on a business, goods held or used for the purposes of the business are put to any private use or are used, or made available to any person for use, for any purpose other than a purpose of the business, whether or not for a consideration, the usage or making available of such goods is a supply of services
In case of goods which are a part of business Asset, it may be fixed or current asset (stock), if any such assets are put to any usage other than business usage, then such activity will amount to “supply” and it will be considered as a “supply of services”.
(c) where any person ceases to be a taxable person, any goods forming part of the assets of any business carried on by him shall be deemed to be supplied by him in the course or furtherance of his business immediately before he ceases to be a taxable person, unless— (i) the business is transferred as a going concern to another person; or (ii) the business is carried on by a personal representative who is deemed to be a taxable person.
The provisions in this clause are self-explanatory, what one can conclude on this basis is that, in case of closure of business, it would be assumed that the business assets have been supplied and the GST liability would occur on the basis of the transaction value generated on sale. Only in case a business is transferred in the manner specified along with assets being taken over, in such case there would be no supply and thus there won’t be any tax liability.

5. Supply of Services
   (a) renting of immovable property
   The discussion in respect of this has already been covered kindly refer to point number 2 above.
   (b) Construction of a complex, building, civil structure or a part thereof, including a complex or building intended for sale to a buyer, wholly or partly, except where the entire consideration has been received after issuance of completion certificate, where required, by the competent
   authority or after its first occupation, whichever is earlier.
   In case of construction services, GST is applicable. While purchasing a residential or a commercial building, it is a deeming fiction of law that the buyer is in receipt of construction services even when ultimately he is to become the owner of an “immovable property”. However there is a bench mark in respect of levy of tax on construction services. The transaction of acquiring immovable property will be first considered as availment of construction services only if any part of the consideration is paid prior to issuance of completion certificate by a competent authority or first occupation of such immovable property.
   Eg: AB Builders has announced the launch of its new building and the bookings are open just by paying a token amount of Rs 5001. The payment of remaining consideration is to be made over a period of 3 years in specified installments. The completion certificate would be issued after 2 years 10 months subject to completion of building. In such case, GST would be applicable, as part consideration is received prior to issuance of completion certificate.
   Eg: AB Builders has a project which in which the building is entirely ready and has been given the completion/occupation certificate. After the issuance date of certificate Mr M books a flat in this building. In such case, as the entire consideration would be received after issuance of completion certificate/occupation certificate, there would be no GST liability. This would be purely a case of sale of immovable property by “AB Builders”, which is outside the scope of GST Laws.
   (c)Temporary transfer or permitting the use or enjoyment of any intellectual property right An agreement entered in respect of transfer of right to use any intellectual property rights, on the basis of agreed terms is considered as a “supply of services”
   Eg: A scientist has patents registered in respect of technology developed by him. He enters into an agreement with a company which would use the technology for a period of 3 years and would be paying consideration as per agreed terms. Such agreement of “temporary transfer” of right to use technology will be considered as a “supply of services”.
   (d)development, design, programming, customisation, adaptation, upgradation, enhancement, implementation of information technology software
   Software industry has loomed large and has grown in multifold manner over the period of last 20-25 years. Thus there has been a variety of services across the software line of business. Any type of service which can be encompassed under the aforementioned categories would be considered as a “supply of services” under GST.
   (e) agreeing to the obligation to refrain from an act, or to tolerate an act or a situation, or to do an act
   Any agreement by virtue of which a person may be refrained from participating in any venture or would be restrained from conducting any activity against which consideration would be payable, such agreement is also considered as a “supply of service”. These type of agreements were essentially brought under the taxation net under the erst-while service tax laws. Ever since, such agreements are charged to tax. The roots of such act of abstinence can be traced in the “Indian Contract Act 1872”. In the modern business era, where there are “anti-competitive agreements” or “contracts of restrictive trade”, the applicability of this category of service comes into picture.
   (f) transfer of the right to use any goods for any purpose (whether or not for a specified period) for cash, deferred payment or other valuable consideration.
6. Composite supply The following composite supplies shall be treated as a supply of services, namely
   (a) works contract as defined in clause (119) of section 2 Works contract usually is a composite contract consisting of goods and or services or a combination of both. Works contract is in relation to immovable property, it may be in relation to construction, repairs, renovation, alteration etc. In the pre-gst regime, “works contract” was subject to huge number of litigations. Whether to tax it as “sale of goods” and charge it to “VAT” or to tax it as “provision of services” and make it subject to “Service Tax”, was the constant factor of dispute. The position under GST laws however is far more settled, as now the supply by way of works contract, by virtue of Schedule-II has been identified and classified as “supply of services”.
   (b) Supply, by way of or as part of any service or in any other manner whatsoever, of goods, being food or any other article for human consumption or any drink (other than alcoholic liquor for human consumption), where such supply or service is for cash, deferred payment or other valuable consideration.
   The Pre-GST regime saw levy of “VAT (Abated)” as well as “Service Tax (Abated)” on activity of serving food in a restaurant/eating joint. However vide introduction of Schedule-II, the activity of serving and selling food and beverages in a restaurant will be considered as a “Supply of Service”.
   7.Supply of Goods
   The following shall be treated as supply of goods, namely Supply of goods by any unincorporated association or body of persons to a member thereof for cash, deferred payment or other valuable consideration
   

Schedule-III: ACTIVITIES OR TRANSACTIONS WHICH SHALL BE TREATED AS NEITHER SUPPLY OF GOODS NOR SUPPLY OF SERVICES
This schedule envisages transactions which would be considered neither supply of goods nor supply of services. This is not a totally new introduction under the Indirect tax laws. Under the Pre-GST regime, “Negative list of services” existed. This list covered a certain transactions which were not liable for levy of service tax. On the lines of the same rationale of law, the Schedule-III has been introduced. Following are the supplies which constitute neither supply of goods nor supply of services.

(a) Services by an employee to the employer in the course of or in relation to his employment. However any services provided by the employer which are over and above the employment contract, would be liable for levy of GST.
(b) Services by any court or Tribunal established under any law for the time being in force.
(c) the functions performed by the Members of Parliament, Members of State Legislature, Members of Panchayats, Members of Municipalities and Members of other local authorities.
(d) the duties performed by any person who holds any post in pursuance of the provisions of the Constitution in that capacity; or the duties performed by any person as a Chairperson or a Member or a Director in a body established by the Central Government or a State Government or local authority and who is not deemed as an employee before the commencement of this clause.
(e) Services of funeral, burial, crematorium or mortuary including transportation of the deceased.
(f) Sale of land and, subject to clause (b) of paragraph 5 of Schedule II, sale of building.
(g) Actionable claims, other than lottery, betting and gambling.

Disclaimer: The views provided above are on the basis of our understanding of the GST Laws, Rules and Regulations. The adjudicating or Judicial Authorities may or may not agree with the views expressed above.