In the matter of M/s. Enpay Transformers Components India Pvt. Ltd., the applicant has stated that the company is importing goods from the Holding company located at Turkey namely M/s. Enpay Endstriyel Pzarlama ve Yatirim A.S. for which the payment terms is 120 days from the date of invoice for import of goods and if the company M/s. Enpay Transformer located at India does not pay to Holding company located at Turkey (outside India) on due date, the holding company is charging interest on late payment.That the company has obtained bank credit facility from CITI Bank based on the Corporate Guarantee issued by holding company Enpay Endustriyel Pazarlama ve Yatirim A.S. and they have paid Stamp tax in Turkey as per their land rules and they have raised reimbursement invoice of said payment to ENPAY India.The applicant has asked the following questions seeking Advance Ruling on the same:1)Whether liability to pay GST on Reverse charge arises if amount is paid as interest on late payment of invoices of imported goods? If yes, then at what rate?2)Whether liability to pay GST on Reverse charge arises if amount is paid for reimbursement of Stamp tax paid as a pure agent by M/s. Enpay, Turkey on our behalf?The Authority for Advance Ruling observed that as per Section 7(1) (d) of CGST Act, 2017, the activities to be treated as supply of goods or supply of services are covered in Schedule-II. As per Entry No. 5(e) of the Schedule-II, agreeing to the obligation to refrain from an act, or to tolerate an act or a situation, or to do an act shall be treated as supply of services. Moreover, as per Section 15 of CGST Act, 2017, the value of supply of goods or services or both shall include interest or late fee or penalty for delayed payment of any consideration for any supply. Therefore, it was held that the payment of interest by the applicant would be covered under the supply of services under Entry No. 5(2) (e) of Schedule-II of the CGST Act, 2017 and would be liable to GST under reverse charge basis. The rate of GST would be the same as the rate of IGST applicable on the imported goods.The applicant had stated that they have submitted a copy of receipt of the Stamp tax paid by the Stamp Tax Office, Turkey. However, since the documents are in foreign language (perhaps Turkish), which is not understandable to AAR and since no English translation of the same has been made available. “We are not able to make out whether any of these documents pertain to receipt of stamp tax issued by Stamp Tax Office, Turkey or otherwise. The applicant should provide proper documentary evidence such as financial records etc. of the supplier. Since no such documents have been produced by the applicant”.The ruling of AAR for the second question asked by the applicant is the applicant is liable to pay GST on reverse charge basis on amount paid for reimbursement of Stamp tax paid by the supplier M/s. Enpay Turkey on behalf of the applicant, since the supplier of the applicant does not fulfil/satisfy all the conditions required for being a ‘Pure agent’ in terms of the provisions of Rule 33 of the CGST Rules, 2017.