GST – Tamil Nadu AAAR - Taxability of gift voucher, gift cards, Pre-Paid Instruments (PPI) – interpretation of term ‘Voucher’ – Time of supply – supply of ‘goods’ or ‘service’ - Actionable claims – Double Taxation - HELD - Voucher, being an instrument used as consideration to settle an application, is a type of money - even if voucher is not recognised by Reserve Bank of India, it would still form a means of payment of consideration - when a voucher is issued, though it is just a means of advance payment of consideration for a future supply, sub-section (4) of section 12 and Section 13 determine the time of supply of the of the underlying goods or services. Voucher per se is neither a goods not a service. It is a means for payment of consideration - under GST law, Voucher is recognized as an instrument of consideration, in non-monetary form, for future supply - since voucher is only an instrument of consideration and not goods or services, the same is not classifiable separately but only the supply associated with the voucher is classifiable according to the nature of the goods or services supplied in exchange of the voucher issue - The Order of the Advance Ruling Authority is modified to the extent that the time of supply of the gift vouchers / gift cards by the applicant to the customers shall be the date of issue of such vouchers and the applicable rate of tax is that applicable to that of the goods - there is no need to determine whether voucher is an actionable claim to arrive at a conclusion that it is neither a goods nor a service – answered in favour of appellant

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