Advance Ruling- Levyu of GST-  The Applicant, as Lessor to provide Warehouse to Lessee on rental basis to store Agricultural produce, ie Frunits & Vegetables. The Lessee Purchases these Fruits & Vegetables from Farmers and Traders directly and stores the same in the Warehouse of Lessor. Later, the Lessee packs these Fruits & Vegetables without any further processing as such for Sale.

The question which needs to be answered is whether renting warehouse to Lessee to store agricultural produce by the Lessee constitute supply of service in terms of Section 7 the Act, if so, whether it is classifiable as "loading, unloading, packing, storage or warehousing of agricultural produce with Nil rate of GST vide Sl. No. 54 (e) of Notification No. 11/2017 C.T. (Rate) dated 28.06.2017, if not, its GST rate and SAC.

Authority for Advance Ruling, Tamilnadu held that :- 

1. Rental Income received by the applicant from Renting Warehouse to store Agricultural Produce is a consideration for supply and the activity is covered under the meaning of supply of services in terms of Section 7 of the Central Goods and Services Tax Act, 2017.

2. Renting Warehouse to store Agricultural Produce is considered as supply of service, and the same is not classifiable as "loading, unloading packing, storage or warehousing of agricultural produce, with 'Nil' GST Rate under Si. No. 54(e) of SAC 9985 of the Notification-11/2017- C.T. (Rate) dated 28th June 2017.

3. Renting Warehouse to store Agricultural Produce covered under the entry 'Rental or leasing services involving own or leased non-residential property' classifiable under SAC 997212 and it attracts GST @ 18% vide entry Sl. No. 16 (iii) of Notification No. 11/2017 C.T (Rate) dated 28.06.2017.