Classification of supply— In the instant case, the appeal is mainly based upon the following points viz:- a. The facilitation of parking spaces between its employees and Building Authority does not amount to supply of services as per the applicable provisions of CGST Act, 2017, as the activity of facilitation of parking space is not in the course or furtherance of business of software development. b. If the same is considered as supply then the value of such supply would be nil as the same is being undertaken by the appellant as pure agent. c. The input taxes paid/payable by the appellant, for the parking space, should be admissible as input tax credit to the appellant, if the parking facilitation services are deemed as taxable supply of services leviable to GST.

Held that— the appellant is providing right to its employee's to use parking facility on the parking space provided by the building authority and for this work they are collecting certain amount from their employee. Accordingly we are of the view that the activity in question, provided by the appellant, is squarely falls under the Schedule II i.e. “Activities to be treated as Supply of Goods or supply of Service” of the CGST Act, 2017. In respect of question no. 2, the appellant has contended that they are transferring the entire amount collected, from their employees towards parking charges, to the Building Authorities. Accordingly, in view of aforesaid discussion we observe that the value of the services in the present case will be NIL, as the appellant is providing the same in the capacity of a Pure Agent, subject to the fulfillment of the conditions prescribed for “Pure Agent”. In respect of question no. 3, if the 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, we observe that though the activity undertaken by the appellant is a supply of service, in terms of Section 7(1) of the CGST Act 2017, however the value of the service would be nil, as the appellant is acting in the capacity of Pure agent for their employees, subject to the fulfillment of conditions. Accordingly the question becomes redundant.