M/s. Automative Components Technology India Private Limited a registered dealer under GST has sought Advance Ruling on: Whether GST will be applicable on the transfer of title in moulds from applicant to Indian buyer, and if yes, whether the Indian buyer would be eligible to take credit of the GST paid to the applicant for said purchase. M/s. Automative Components Technology India Private Limited (ACTIPL) is engaged in the supply of automotive components for various sectors of the automotive industry. They supply such parts to a wide range of customers which inter – alia include moulds and tools. They agree to supply certain parts, including the moulds to an Indian company. In this regard, they placed an order for manufacturing the said parts and moulds on a Thailand Company. Accordingly, the foreign supplier manufactures the parts and the same are physically imported into India. However, the moulds developed by the foreign supplier are retained in Thailand and are not physically imported into India. Thus, there is only a transfer of ownership in the mould from the foreign supplier to Applicant and the foreign supplier retains the physical possession of the moulds. Further, a separate invoice was issued by the foreign supplier for moulds, against this ACTIPL also raises separate invoices on the Indian buyer. ACTIPL stated that only the title in moulds are transferred to the Indian buyer, wherein the moulds physically continue to remain in possession of the foreign supplier and were disposed of as waste. The decision was made considering Section 7 of the CGST Act 2017, where Schedule II Entry S. No. 1 states that the transfer of the title in goods is a supply of goods. From this, it was evident that ‘transfer of the title in goods’ is supply of goods. In the case at hand, there is transfer in title of moulds for consideration and the supply is in the course of business, therefore, the same constitutes supply of goods and GST is liable to be paid on such supply. Hence, GST is applicable on the transfer of title in moulds from the applicant to the India buyer and question of credit does not arise as same is not in the ambit of this authority as per Section 97(2) of the Act.