employees cannot be treated as a supply of service of health insurance by Jotun India Ltd. We do not agree with this argument of the appellant for the reason that, the question before the Maharashtra AAR was whether the activity amounts to a supply of service or not. In the case before us, there is no dispute that there is a supply of service by the Appellant to the employees who use the transport facility. The question is whether such service is an intermediary service or a facilitation service between BMTC and the commuters. Therefore, the decision of the Maharashtra AAR in the Jotun India Pvt Ltd case has no relevance to the issue before us. The Appellant in this case, as part of its business activity of operating and maintaining the International Tech Park, also undertakes to anange for the transport for the staff employed with it and by the various corporate clients of the Tech Park. In this connection, the Appellant charges a fee on their clients for whose employees they are providing the transport facility. This is a service provided by the Appellant to their clients' employees on their own account on a principal to principal basis as part of their business activity. The Appellant also acknowledges that they are rendering a service to the employees of their clients and they are also charging and collecting GST at l8o/o on such a service fee. This is evident from the copy of the invoice dated 10.07.2019 raised to M/s Applied Materials India Pvt Ltd, Bangalore for the issue of bus passes for the period from 01 .07.2019 to 31.07.2019, which was fumished by the Appellant. It is also seen from clause 13 of the Agreement with BMTC that all commuters travelling in the buses engaged by the Appellant shall possess the identification cards and the monthly passes issued by the Appellant. This evidences that the bus passes procured by the Appellant from BMTC are issued by them to the commuters as part of the service provided by them on their own account. If they were merely facilitating the service or acting as an intermediary, as claimed by them, the bus passes would have been issued by BMTC to the commuters. In the light of the above discussions, we agree with the ruling given by the lower Authority and hold that the service provided by the Appellant in arranging the transportation of the employees is not rendered in the capacity of an intermediary and is not a facilitation service between BMTC and the commuters. The service of transporting the employees of the corporate clients of the International Tech Park is rendered by the Appellant on his own account on a principal to principal basis for a consideration.
