Case of Jolarpettai Veeramuthu Sreedhar, AAR Tamil Nadu Ruling dated 9th January 2026. The application seek clarity on the GST implications of non-compete and non-solicitation fees received pursuant to a share sale transaction. The applicant was a shareholder of a company engaged in bespoke software development, whose entire shareholding was sold to two purchasers, i.e. one located outside India and one in India, along with the goodwill of the business. AAR ruled that the activity of applicant agreeing to refrain from doing an act is Supply of Services. The services rendered to party located outside India, qualifies as export of service, is ‘zero rated supply’, attracting NIL rate of GST. The services to parties within India will attract GST as applicable.