Case of Sampurnam Hosieries Impex Private Limited, AAR Tamil Nadu Ruling Dated 4th May 2026. AAR held that the commission paid to the director, who is a foreign national, for the purpose of marketing and sourcing of orders is liable for GST as it falls under the scope of ‘Import of Services’ under Section 2(11) of the IGST Act, and is also liable for tax under reverse charge.
— There will be no tax liability in case marketing agents are foreigners and they are paid 20% of the invoice value for marketing, as GST is not payable on commissions paid to marketing agents located in foreign countries because it falls under the category of intermediary services as per Section 2(13) of the IGST Act.
— There will be certain tax liability in case of clearing and forwarding done in a foreign country by a foreign company or individual, as GST is payable on charges paid to C&F agents and it falls under the scope of ‘Import of Services’ in terms of Section 2(11) of the IGST Act, and tax is also liable to be paid here under reverse charge.