Dismissed

M/s. Troikaa Pharmaceuticals Ltd.

GST AAAR28 Feb 2025GUJ/GAAAR/APPEAL/2025/07

Case brief

AI extract

What is this about?

The Gujarat Appellate Authority dismissed the appeal filed by M/s. Troikaa Pharmaceuticals Ltd. against an advance ruling. The authority upheld the denial of Input Tax Credit on goods supplied to contractual workers and affirmed GST levy on amounts recovered from them for canteen services, ruling that the obligation to provide canteens does not extend to contractual workers under the statutory cir

What did the court decide?

The appeal was dismissed, and the impugned Advance Ruling dated 10.08.2022 was upheld, rejecting the appellant's claim for Input Tax Credit and confirming GST liability on recovered canteen charges.

M/s. Troikaa Pharmaceuticals Ltd. — GST and Indirect Tax | GST AAAR (2025)

¶1

¶2

GUJARAT APPELLATE AUTHORITY FOR ADVANCE RULING GOODS AND SERVICES TAX . rffl'o' uUmRnxrr D/5, RAJYA KAR BHAVAN, ASHRAM ROAD, AIIMI,IDAIIAI) - 3tt0 009.

¶3

ADVANCE RULTNG (AppEAL) NO. GUJ/GAAAR/APPEAL12}25 107 (IN APPLICATION NO. Advance Ruling/SGST&CGST 120221 AR/09)

¶4

Date: 2{.2.2025

¶5

Nameandaddressofthe appellant	M/s.TroikaaPharmaceuticalsLtd., GF-1,Groundfloor,CommercialHouse-1, SatyaMarg,Boadakdev, Ahmedabad, Gu.jarat-380 054.
GSTIN ofthe appellant	24AABCT6866HIZ4
JurisdictionOffice	Office oftheAssistant CommissionerofState Tax, Unit-9,Range-3,Division-I, Ahmedabad.
AdvanceRulingNo.and Date	GUJ/GAAA[VW2022138dated10.08.2022
Dateofappeal	30.09.2022
Dateol'Personal I.{earing	2r.1.2025
Pr.r"nt loithcappcllani	ShriSandipGupta,CA&ShriArunGovlani, CA

¶6

At the outset we would like to make it cle ar that the provisions of the Central Goods and Services Tax Act, 2017 and Gujarat Goods and Services^'fax Act, 2017 (hereinafter referred to as the 'CGS'| Ac! 2017 ' and the 'GGST Act, 2017 ') are pari materia and have the same provisions in like matter and differ from cach other only on a few specific provisions. Thcreforc, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act, 2017 would also mean reference to the coffesponding similar provisions in the GGST Act,2017 .

¶7

The present appeal is filed under Section 100 of the CGST Act, 2017 and the GGST Act, 2017 by N4/s. Troikaa Pharmaceuticals Limited, (hereinafter referred to as'appellant') against the Advance Ituling No. GIJJ/GAAAIV P.U2022138 dated 1 0.08 .2022.

¶8

J..| Briefly, the facts are enumerated below for ease of reference:

¶9

the appcllant is engaged in thc manufacture, salc & distribution of pharma products and is registcrcd with thc department; ,4,

¶10

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¶11

¶12

. the appcllant has appointed a CSPI;

¶13

. the appellant provides subsidized canteen facilitics to its employees & contractual workers;

¶14

the appellant recovers 50% of the amount from the employees;

¶15

. that as far as security service contract workers is concerned, the canteen service provider raiscs bill lbr only 50% of thc amount as thc rest of thc amount is being dircctly paid by thc individual workcrs to thc scrvice providcr.

¶16

In view of the foregoing facts, the appellant had sought Advance

¶17

Ruling on the following questions, viz:

¶18

l- Whether GST' shall be applicable on the amount recovered by the company, Troikaa Pharmaceuticals Limited, -fro* employees or contractual workers, when provision of third-party canteen service is obligatory under section 46 of the Factories Act, 1948?

¶19

Whether input tax credit of GST paid onfood bill of the Canteen Service Provider shall be available, since providing this canteen facility is mandatory as per the Section 46 of the l,.actories Act, 1948?

¶20

Consequent to hearing the applicant, the Gr.rj arat Authority for

¶21

Advance Ituling [GAAR.], recordcd the following findings viz

¶22

that in terms of the circular No. 1721412022-GST dated 6.7.2022, the benefit provided by employer to its employees in terms of contractual agreement is not supply;

¶23

a that in terms of section 17(5)(b), ITC is available on GST^{paid where} it^is obligatory to provide a benefit by an employer to an employee; that the said sub-section^read with the clarification issued vide circular No. 1721412022-GS1' datcd^{6.7.2022, I'l'C} of the GST paid on canteen charges is available to the applicant on the^goods supplied to the employees of the applicant as it is mandatory to^{providecanteen} facility uls 46 of the Factories Act, 1948;

¶24

a that as far as providing cantccn facility to contractual workcrs are^{concerned, it was} hcld as undcr:

¶25

thc contractual workcrs do not form part of the employce^as they^{are not on} the pay roll of the appellant;

¶26

that the term 'employed' is not defined under^GST &^{hence in terms of the} dictionary meaning, it means engaged or occupied in^{the performanceof the} work or hired to perform labour;

¶27

that relying on thc tcst of establishing cmployer-employce^{relationshipas} spelt out in the case of Balwant Rai Saluja, by the Hon'ble^{SC,the appellant} has entered into a contract with the contractor; that^{the amounttowards} salary/wages is paid to the contractor;^that the^{instant case does not passthe} test of employee-employee relationship &. hence not^{covered under the} ambit of cntry 1, Schcdule III of the CGST Act, 2017.

¶28

that even though therc is no^profit,as claimed^{by the appellant on the supply} of food to contractual workers, there is supply^{in terms of section 7(1)(a),} ibid;

¶29

since the appellant recovers the cost of^{food from its contractualworkers} thcre is consideration as dcfincd u/s 2(31),^ibid;

¶30

a that as far as availment ol I'l'C on^{cantecn chargcson the lood supplicdto} contractual workers is conccrned, the ruling^{held that:}

¶31

the contractual workers are not^{covered under the employee-employer} relationship;

¶32

1 Cantccn Service Providcr

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¶35

that in terms of provision of chapter V of CLRA2, 1970, the^labour contractor shall provide the canteen facility to the labour employed^{by the} contractor;

¶36

that there is no mandate that the appellant is required to^{providecanteen} facility to the contractual worker;

¶37

that since providing canteen facility to contractual workers^{is not obligatory,} ITC is blocked in terms of section 17(5) of the CGS'| Act, 2017.

¶38

The GAAR, vide the impugned ruling dated 10.08.2022, held^as

¶39

follows:

¶40

8U!,{NG

¶41

l.^(;S"l'. at the hands ot'Mis^'[roikua.i.s not^{leuinblq on thc an]ounl reprcscnting thc} emnlLvees portion tr|. cnlcn chargcs.^{which is collsctedh5' IVls "l'roiktaand} prid to thu Canteen scn,icc prosidcr.

¶42

i.^(iSl. at thc halrds ol'|vl,is I'roikua. i: lcviable on^{thc antount rcprcscntirlgthc} r:onfr$cttrut wnrkrr portion ol^{cilnlecn charg*s.u'hiuhis r:tlllcr:tcd h1' Mls} I roikaa and paid to thc Canteen sen'icc^pnn'itltr.

¶43

L l'f(l on GS'l' puid on catltc.:n facilitl^{is tdnrissibleto Mls 'l'roikaa undcr Sectintt} l7 (5Xbl of CGS"I' Act on the ltxxl supplir;d to Empl*Jecs^{ol'tlrc c$mpan]'suhicet} to the contlition that burdc'n nf^{(iS'l'hal't nut lrccn ptsscdon to thcr:rrrpkr.r'ctstl'} the corupnl.

¶44

l'l( on GS'l'paid on canteen lirr:ilit3'is ngt-dil-Uj$j-blg to Mis'l'roikaa^undcr Scctinn l? (sxh) uf'CtiS't'Att or! thc lbod supplied to^{qsuttractual rvorktrr} supplicd by' lahour contrilctor.

¶45

Bcing aggricved by the impugncd ruling i.e. dcnial of I'fC on canteen services provided by the appellant to contractual workers and levy of GST on food charges recovered from contractual workers, the appellant is belorc us, raising the following contentions, viz

¶46

a thc GAAIT did not give the appellant an opportunity of being heard and hence there is violation of natural^justice;

¶47

a that in terms of clarification at issue no. 3 vide circular dated 6.7.2022 & ScheduleIII of thc CGST Act, 2017, the appellant is eligible for IfC on canteen serviccs as it is undcr lcgal obligation; that no GS't' amount is lcviablc on thc amount rccovcrcd from contractual workers for canteen services, respectively;

¶48

a that while relying on section 16 of the CLRA,1970, the authority ignored sections 20, 2l &. 29, ibid;

¶49

a that the appellant is the principal employer of thc contractual employees in tcrms of scction 2(9; that in terms of the CI-ltA, 1970, iI thc contractor docs not provide thc canteen facility it is to be provided by the applicant being a principal employer;

¶50

a that in terms of section 2(I) of the Factories Act, 1948, a worker includes a contractual worker;

¶51

a that the authority ignored paragraph 30(3) of the IIPF Scheme wherein the main and primary rcsponsibility for dcpositing providcnt fund is with the appcllant &. therefore there is an employer-employee relationship;

¶52

a that in terms of the term 'employed' as defined in the impugned ruling, it includes employees hired to perform labour;

¶53

2 Contract Labour (Itcgulation & Abolition) Act, 1970

¶54

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¶55

¶56

a that the contractual workers arc huge in numbers & all of them are working in the factory premises of the appellant which is possible when they are working under the complete control and supervision of the appellant;

¶57

a that though there is no formal employer-employee relationship, the appellant as principal employer will still be responsible for all workcrs dircctly or indircctly cmployed by thc appcllant.

¶58

Personal hearing in the matter was held on 21.1.2025, wherein Shri Sandip Gupta, CA 8L Shri Arun Govlani, CA appeared on behalf of the appellant and reiterated the grounds of appeal.

¶59

The appellant thereafter vide additional submission through email dated 29.1 .2025, addressed to Registry, stated as follows:

¶60

Witlr reference to onr heorirg held on Zt{1-2025, we ore ottochirg herenith followirgr

¶61

Hence, in view o{ the okve, we ogoin would like to reiterute ard drw your kind ottention torruds followirq,

¶62

!*l 'd.vort^{F0vi!i06oG0lrmdy i1.JrtiolEdin 0{r riilsiorl}

¶63

tllerrd.l0 it a{plqE ! udeory lorforlkli'rE hi,9 hfg.cc

¶64

ot rtctd .rpb!rr.

¶65

. l{e ore sttoihirg the r.elermnt pnovisions of OnI Act od Foctories act vhich }Ew drcdy been inchdd in our s6rnission,

¶66

. We hsve dnead mentioneo ow detoile/ orglmmts in our suhnission.

¶67

The relevant extracts of the contract entered into with M/s. Tirupati

¶68

Enterprises, are reproduced below for ease of reference viz

¶69

ilON.I'I(ACT AGRLET4 IJN'I' IJOR I,,,\BOT JR S [,I I)I}I-,\T

¶70

AN ARTICLE OF AGIIF:IiMENT MADE ON ]'HlS 2l'1 Jusc 2024 betrvcen l\t/s T'roikrr* I'harmtcuticals Ltd., in coryroration under the cornpany.ACT 1950 having its rugister officc at Conrnterce House 1, Satyamarg Bodakdev, Ahmedabatl - -l[I0054 (which cxpression shall include llrat hcirs e.tecutors and assigns), herein aftcr rcfirred to as the 'Comparly' txr orle piln and N{/S Tirupati Entcrprise having thuir ntTrce at Lrrnc No.-8. Post Oflir.:c lload. (llcrnent Tuwn, Dehradun. {R'}rich exprcssir.xr shall inch.rcle tlrr"ir heirs executors nnd assigns), herein aliur rcli:rrerl to trs thc 'Contra$tor' on the other part.

a of9

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1-1.1-hc conttactor n:ust courllly w'ith all the: appliuuble intlustrial lau,s such as Faclorics act" Employcus Frovideut Fund and lltisc. Ilrovisions acl, ESIC Acl, Minimunr Wages Acl, Pa.vment of Wages Act, Bonus Act. Cratuity Act, 1"he contract labour (Rcgulotion and aholition) Aut l9?0 ctc, and shall suhnrit all the f<rrms and rcturns in tinre *nd nlsn maintain records and registers rcquirc<l as p$r thc act. Thc Contractrlr shall producc thc rrxords to lhc cornpillly sxesutive rrs and u,[lt:.n demanded.^'l]rc contrtctor will be responsible for all the cclilsequqncrls including penalties if any for non cornpliance with respert to the applicablc Introur lurvs. Any deviation in statutory cornpliancu *"ill lend to pennlty as pcr Aq$till$gc B No A,RFcxu re,-!l-Ls ? ttnchffl)^.

¶75

The corrtractor shall alsei c.olnply with all uthrr lahnur anrl industrial lnr+'s and such other Acts and $tatus fls miry be applicahlc to the contrrctor ltom tirne to tinre and maitrtaitr thc nccessary documents/rccords atrd submit tei crtncent Authorities.

¶76

Thc c$trtrflctor shnll milke ll thc^{stlltutory dctluctionsti'rx"lttltc sirl}r)'/u'a$s p3'fihlc trr t[c 11'6rk$r's lou';rrtls HSIC'. ff.^{Litl",()ur'\rcltirre Furtcl artd prolcssilrt;.rl lit,\ r:tc its II]aY llu} applicnhlc ft'rlnr time to timc and suhnlit^{ir copy of tlre uerlillcatsI prcof that all thc} $t4tutury ducs iclutling HSIC ilnd P[; hns bccn F$id^{hy hirrr in li}tc. Stfitcrnctttot'such tle$uutions and fa),"nlcills firir{lc shtll^{bc sutrrttitt*tl alons witlt tlts cnnlrilctor'snrorrthly hill.}

¶77

t?. f"trc c$rlrpny 'ill not in any^rvny hc^{rr;rFonsihlcllrr not'l}c(xllplianccol'arlylubtlurlarvs, applicutrle to the contrfict anurloy'ec. lf^{thc erltnpilruris reqmired to nrakeany} Pit)ryItrnts undcr llny sttuteiry regulatiorrs^orr lrehnlf^{n{'thcsontrflct(rr"r' duc t{} non c{}n}pliilIlL1e or} lirilurc ot-tire corllr$ct(rr, tlrc cornllln),sltall^{tlutluct tlte sltt:e trurntltt ittnuuntpxy}ilhlc to tire crurtractor" duriltg tlte pcrid ol'c()ntrat^{or tltcrcaficr.}

¶78

Bs it clcarly unr.lerstood and agreed that by this^{dced, no rclationshipof the ernploytrrflnd} employcc is crctterl bet*,een the^ccxnpany and thc^{rvorkcrs errgagedbv the contractor.}

¶79

We have carefully^gone through^{and considered the appeal papers,} written submissions filed by the^{appellant, submissionsmade at the time of} personal hearing, the impugned ruling,^{additional submissions madepost} hearing and other materials available^{on record.}

¶80

1 1. Before dwelling on to the issue,^{we would like to reproducerelevant} portions of GS-l' Act and circular lclarification^{for easc of rcfcrence viz}

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ODS AND SERVICES ACT. 2017

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Section 17. Apportionment of credit and^{blocked credits.-} (5) Ir{otwithstanding anything contained in sub-section⁽¹⁾ of section l6^{and sub-} section⁽¹⁾ o./'section lB, input tax credil shall^{not be at,oilableinrespect of the} .fbllowing,^namely:- ,r-'ffi h\

¶83

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(b) 3 [the following supply of goods or services or both-

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(i) food and beverages, outdoor catering, berruty treatment, health services, cosmetic and plastic surgery, leasing, renting or hiring of motor vehicles, vessels or aircraft referred to in clause (a) or clause (aa) except when used for the purposes specffied therein, ldb insurance and health insurance:

¶89

Provided that the input tax credit in respect of such goods or services or both shall be available where an inward supply of such goods or services or bolh is used by , registered personfor making an outward taxable supply of the same category of goods or services or both or as an element of a taxable composite or mixed supply,'

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(ii) membership of a club, health and/itness centre; and

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(iii) travel benefits extended to employees on vacation such as leave or home travel concession:

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Provided that the input tax credit in respect of such goods or services or both shall be available, where it is obligatory for an employer to provide the same to its employees under any law.frtr the time being in /brce. I

¶93

2-GST dated 6.7.2022

¶94

	Clarification	onvariousissuesofsectionl7 5 oftheCGSTAct
aJ	Whethcrthcproviso atthccndo[clausc (b)ofsub-scction(5) ofscctionI1ofthe CGST Act is applicabletotheentire clause(b) or the	VidcthcCentralGoodsandScrvicc'l'ax(Amcndrnent Act) 2018,clausc(b)ol'sub-scction(5)o[soction 17ofthc CGSI'Actwassubstitutedwith effccrfrom01.02.2019. Aflerthesaidsubstitution,theprovisoaftersub-clause (iii)ofclause(b)ofsub-section(5)ofsection17ofthe CGST Actprovidesasunder:
	said provisois applicablconlyto sub-clause(iii)of clause(b)?	"Providedthatthcinputtax creditinrcspectofsuch goodsorscrviccsor both shallbeavailable, whercitis obligatoryforanemployertoprovidethesameto itsemployeesunderany lawforthetimebcingin force."
	uisites vided I cm	2.^'l'hcsaid amcndmcntinsr"rb-scction(5)ofscclionl7ol'thc cGSl'Actwas madebascdontl-rcrecornrncndationsol'GS'l' councilinits28tl'meeting.J'heintentofthe said amendment insub-section(5) ofsection77, asrecommendedby the GSTCouncilinits 28tl'meeting, wasmadeknowntothe tradcandindustry throughthcPressNotc on Itccommcndationsmadc duringthc28t1,mcctingofthc GS'l'council,datcd21.01.2018.Ithadbccnclarificd"that scopeofinputtax creditisbeingwidcned,and itwould rlowbemade availableinrespectofGoods orservices whioh areobligatoryforanemployertoprovidetoits employees,underanylawforthetirncbeingin force." 3.Accordingly,it isclarifiedthatthe proviso aftcrsub- clausc(iii)ofclause(b)ofsub-scction(5) ofsccrionl7ol'the CGSTActis applicable to the wholeofclause(b)ol'sub- section 5 ofsection17oftheCGST Act. rtothe cm contractual I AS agrcement
5	Whcthervarious perquisitesprovidcd bythc cmployertoits employeesintermsof contractualagreement enteredintobetween thcernploycrand the	1.ScheduleIIItothecGS'l'Actprovidesthat"servicesby cmployeetotheemployerinthecolrrseofor inrelation to hiscmployment"willnotbcconsidcredassupply ofgoodsorservices and henceGST is notapplicableon services renderedbyemployeetoemployer providedthey areinthe courseofor in relation toemployment.
	crnployccarcliable for GSI'?	2. Anypcrquisitcsprovidedbythccmployertoits employecsintermsofcontractualagreementcntered intobetween theemployerandthe employee are in ided em the servlces totheem

¶95

¶96

t,) il:. \ , 11.,:\ -/-r.1' ff""

¶97

¶98

his employmcnt. It follows thcre from^{that perquisites} provided by the employer to the employee^{in terms of} contractual agreement entered^{into betweenthe} employer and the employee, will^{not be subjected to GST} when the same are^provided in^{terms ofthe contract} between thc erl and em

¶99

On going through the^{prayer,we find that the appellant is} aggrieved against the impugned^{ruling dated 10.08.2022,only to the extent} that:

¶100

tal^{it holds that GST at the hands of the appellant is leviable on the} amount representing contractual^{workerportion of canteen charges} which is collected by the^{appellant & paid to cSP; and}

¶101

tb]^{it holds ITC on canteenfacility is not admissibleunder section} f Z1S)1U) of the CGST^Act,2Ol7 ,^{on the food supplied to contractual} workers.

¶102

The primary averment^{raised by the appellant is that while} relying on section l6^{of the CLI{A, 1970, GAAIT ignored sections 20,21 &"} 29, ibid;thatin terms^{of section 2(g),the appellant is the principal employer} of the contractual^{employees and under CLRA if the contractor does not} provide the canteen facility^{it is to be provided by the appellant;that in terms} of section 2(l) of^{the FactoriesAct, 1948, workerincludes a contractual} worker. The other^{averments have already been listed in para graph 7 and is} not being repeated^{for the sake of brevity.}

¶103

t4. Section 20 &,21 of^{CLRA,1970, is reproduced below for ease of}

¶104

referen ce viz

¶105

Liability of principal^{employerin certaincases}

¶106

(t) If any i*iiityrequiredio^{be providedunderSection 16, Section17, Section18} or iection l9 for^{the-benefitof the contractlabour employedin an establishmentis} not providecl by the^{contractorwithin the time prescribed therefor, such amenity} ;;hail be proviied by^{the principal employerwithin such timeas may be prescribed.}

¶107

(2) All expenses incurred by the^{principal employerin providingthe amenitymaybe} recoverea Oy the^{principal employer} from^{the contractor either by deduction fro*} any amount payable^{rc- the contractor under any contractor as a debt payableby} the contractor.

¶108

2 t. Responsibility for^{paymentof wages.-}

¶109

(l) A contractor shill be responsible for^{paymentoJ'wages to eachworker} employed by him as contract^{labour and such wagesshall be paid before the expiry} o.f such period as may be prescribed.

¶110

(2) livery principal emplol,er shall^{nominate0 representctliveduly} O him to be present at the^{time oJ'disbursement of wages bythe contrac} 1 %\j! be the duty of such representative^{to certify the amountspaid} € __) !q$:r IP ,qB&'' t.1.i'j,l'.,( i,"*.

be prescribed.

manner

may

(3) It shall be the duty of the contractor to ensure the disbursement ofwages in the presence of the authorised representative o.f the principal employer.

¶117

Q)^{In casethe contractor} fails^{to make payment} of wages within the prescribed period or makes short payment, then the principal employer shall be liable to make payment of wages in full or the unpaid balance due, as the case may be, to the contracl labour employed by the contractor and recover the amount so paid .fro* the contractor eilher by deduction./iom any amount payable to the contructor crnv contracl as a debt payable by the contractor.

¶118

Relying on sections 20(2) and 2l(2), it is averred that though statutorily it is thc contractor who is rcquircd to providc the amcnity to thc contractual workers in terms of section 16, ibid, the onus shifts on the principal employer ie the appellant in case the contractor is not providing the same. Two things are therefore clear [a] that statutorily it is the contractor on whom the CLRA Act has entrusted the task of providing the amenity; and [b] the responsibility shifts on the principal employer ie appellant in case of the contractor is not providing the same. However, one cannot ignore the fact that the section also states that all expenses incurred by the principal employer in providing such amenity may be recovered from the contractor either by deduction from any amount payable under any contract or as a debt payable by the contractor.

¶119

1 5. I'he GAAR in its impugned ruling, vide paragraphs 2l to 2l .7 and thereafter in paragraphs 22 to 29 and 3 | , has provided its reasoning, which has not been rebutted by the appellant. The appellant in his averments assumes of a situation wherein he is thrusted with the responsibility as a primary employer, which would arise only in case the contractor fails in his statutory obligation. The assumption so made is not supported by factual evidence. Further, the copy of the invoice rcproduced at paragraph 21.6 of the impugned ruling, the facts belie these averments and assumptions. It clearly depicts that the contractor has been paid the gross amount which includes salary, allowances such as cantecn facility, provident fund, etc. Wc arc also unable to pinpoint any averment by the appellant that the contractor has failed to fulfill his statutory obligation, the primary requirement for the onus to shift to the appellant.

¶120

Further, in the agreement with M/s. Tirupati Ente SCS, .tt AUTHg l: Dehradun, the relevant extracts of which are reproduced supra, \ rrq b() z. , .d.)

¶121

¶122

¶123

explicitly states that no rclationship of employcr-employcc^{is creatcd bctwcen} the appellant and the workers engaged by the contractor.^{This being so, the} clarification at serial no. 5, vide circular no. 1721412022-GST^{dated 6.7.2022} relied upon by the appellant to aver that no GST amount is leviable^{on the} amount recovered from contractual workers for^{canteen services, fails since} the clarification states that perquisites provided by the employer to^its employees in terms of contractual agreement entered into^{between them will} not be subject to GST. Further, the clarification at serial^{no. 3 of the said} circular dated 6.7.2022, regarding availment of ITC, would^{also not be} applicable since it is available only in respect of the^{goods supplied to the} employees of the appellant in terms of scction 46 of thc^Factories Act,^1948, which mandates provision of canteen facilities to the^{employees. Further, in} terms of clause 17 of the agreement, appellant also indemnifies^{himself for} any payment made on behalf of the contractor.

¶124

The GAAR has dealt with the issue in depth in the^paragraphs mentioned above. Nothing new is produced before us forcing^us to^interfere with the impugned ruling.

¶125

We therefore, uphold the impugned ruling dated 10.8.2022.

¶126

In view of the foregoing, we reject the appeal filed by appellant M/s. Troikaa Pharmaceuticals Ltd, against the Advance Ruling^No. GUJ/GAAIVIV2022138 dated 10.08.2022, passed by the Gujarat Authority for Advance Ruling.

¶127

k
( Rajeev Topno ) 9- F' E AUTHo 'fi/ )-
Member (SGST) v c9
v
& Iv
:)q tn7-
Place: Ahmedabad '4ic
Date:L{.02.2025

¶128

(B V Siva Naga Kumari) Member (CGST)

¶129

Page 9 of 9

M/s. Troikaa Pharmaceuticals Ltd.

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M/s. Troikaa Pharmaceuticals Ltd.

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