Who we serveServicesResources AboutContact Book Free 15-min Call →
⚖️ Case law & circulars

Key OIDAR Rulings &
CBIC Circulars

Curated analysis of the most important OIDAR GST decisions and official clarifications — explained plainly.

PB
Parmod Bindal, FCA
Founder & Lead OIDAR Specialist · OIDARIndia™
Updated June 2025
Download rulings PDF
Advance authority rulings
Key AAR & AAAR decisions on OIDAR

Advance Authority Rulings have progressively expanded the interpretation of OIDAR, covering more categories of foreign digital services.

AAR — Karnataka
In re: Springer Nature Customer Service Centre GmbH
2019

Journal/database access is OIDAR — but exemption for genuinely non-business government/individual use

A publisher of scientific, technical, and medical journals accessed by registered and unregistered users, including government bodies and individuals, sought clarity on when it must charge GST. The AAR held that GST is chargeable on OIDAR supplies to unregistered persons where used for commerce, industry, business, or profession — but not where government, local authority, or individual recipients use the service for genuinely non-business purposes. The burden of proving non-business use was placed on the applicant.

Takeaway: this case predates the Finance Act 2023 change to the NTOR definition, which removed the "non-business purpose" qualifier — the exemption this ruling recognised is narrower today than it was in 2019.
AAAR — Maharashtra
In re: Amogh Ramesh Bhatwadekar
2021

Online gaming "e-goods" confirmed as OIDAR — reverse charge applies on import

An applicant procuring "e-goods" (in this case, online gaming credits/content) from foreign suppliers via cloud servers sought clarity on GST treatment. The Authority held these e-goods are services, not goods, and fall within OIDAR — Section 2(17) of the IGST Act specifically lists online gaming. Where such services are procured by a registered person in India from a foreign supplier, IGST applies under reverse charge.

Takeaway: digital content resembling "goods" in commercial description is still classified as a service under GST if delivered electronically — the label doesn't change the classification.
AAAR — Karnataka
In re: NCS Pearson INC (department appeal)
2021

The clearest example of the "fact-to-fact" grey area: a ruling reversed on appeal

NCS Pearson, an online testing provider, sought a ruling on whether its "Type-3" tests — a mix of multiple-choice and essay questions, algorithmically scored but with human validation of the algorithm's essay marks — qualified as OIDAR. The original AAR held it did not, reasoning that human involvement in scoring took it outside OIDAR's automation requirement. The department appealed. The AAAR reversed, holding that human validation of an already-generated algorithmic score is still "minimal human intervention," and that from the candidate's perspective the entire service — registration, testing, and results — was received digitally.

Takeaway: this is a genuine, on-record example of two tiers of the same authority disagreeing about where the human-intervention line sits — exactly the "grey area, decided fact to fact" pattern discussed throughout our guides. It's also a caution against relying on a first-instance AAR ruling as if it were final.
CBIC circulars & clarifications
Official CBIC guidance on OIDAR

CBIC has issued binding circulars clarifying OIDAR-adjacent obligations. These are sourced directly from CBIC's own published circulars.

Circular No. 232/26/2024-GST
10 September 2024

Data hosting services to overseas cloud providers are not "intermediary" services

CBIC clarified that when an Indian company provides data hosting services (data centre premises, hardware, power, connectivity, security) to a cloud computing service provider located outside India, this does not meet the "intermediary" definition under Section 2(13) of the CGST Act — the data hosting provider is an independent service provider in its own right, not someone merely arranging or facilitating a supply between the cloud provider and its end users.

Impact: relevant background for any Indian company supporting a foreign cloud/AI platform's infrastructure — this circular addresses that India-side relationship specifically, not the foreign platform's own OIDAR liability to its Indian end users. Note: at the time of this circular, intermediary classification also carried place-of-supply consequences under Section 13(8)(b), which has since been omitted — see the amendment below.
Finance Act 2026 — Section 157
30 March 2026

Section 13(8)(b) of the IGST Act omitted — a major, current change to intermediary place-of-supply rules

For close to a decade, Section 13(8)(b) deemed the place of supply for an intermediary's own facilitation service to be the supplier's location, regardless of where the actual recipient sat — a carve-out from the normal recipient-location rule. The Finance Act 2026 (Section 157) omitted this clause entirely, with Presidential assent on 30 March 2026. Intermediary services now fall under the default rule in Section 13(2): place of supply is the recipient's location, the same as most other cross-border services.

Impact: this changed where an intermediary's own fee is taxed, not who counts as an intermediary — the Section 2(13) definition and the four-condition deemed-supplier test are unaffected. Full treatment, including who this actually affects, in our Marketplaces & Advertising guide.
Circular No. 159/15/2021-GST
20 September 2021

The tripartite-arrangement test for identifying genuine intermediary services

CBIC clarified the conditions for identifying an "intermediary" service: a tripartite arrangement must exist (at least three distinct parties — two engaged in the principal transaction, one facilitating it); the facilitator must arrange or facilitate the main supply without supplying it on their own account; and sub-contractors who actually perform any part of the main service are treated as independent service providers, not intermediaries.

Impact: still fully operative — this is the practical test behind the Section 2(13) definition discussed throughout our marketplace and platform guidance.
Circular No. 242/36/2024-GST
31 December 2024

Recipient's state must be recorded on invoices for OIDAR, online gaming, and e-commerce supplies

CBIC clarified that suppliers of OIDAR services, online money gaming, and taxable e-commerce-operator services to unregistered recipients must record the recipient's state on the tax invoice, irrespective of transaction value — correcting a pattern where suppliers were instead recording their own location, causing tax revenue to be misallocated between states.

Impact: a direct, current compliance requirement — billing systems for OIDAR supplies need to capture and record Indian customer state, not just country.
Foundational precedent
The underlying digital-services classification principle
Supreme Court of India
Tata Consultancy Services v. State of Andhra Pradesh
2005

Software on physical media is "goods" — the classification line that still matters today

(2005) 1 SCC 308. The Supreme Court held that branded, packaged software sold on physical media (like a CD) constitutes "goods" for tax purposes, even though the developer retains the copyright — because the software becomes marketable and capable of being bought and sold once fixed to a medium. This remains the foundational precedent distinguishing software-as-goods from software-as-a-service, and is why OIDAR's narrow physical-media exception exists at all.

Takeaway: this pre-dates GST entirely, but every modern discussion of digital-vs-physical classification for software and data ultimately traces back to this case.
A note on accuracy: every ruling and circular on this page has been independently verified against detailed primary or near-primary sources. Where we found conflicting or unverifiable reports of a ruling elsewhere, we have deliberately left it off this page rather than risk stating something as settled law that isn't. If you're aware of a ruling we should verify and add, we'd welcome hearing about it.
Disclaimer: The above summaries are provided for general informational purposes only and are based on our understanding of the relevant rulings and circulars as at the date of publication. They do not constitute legal advice. OIDAR law and its interpretation continue to evolve. For advice specific to your situation, please consult OIDARIndia™ directly.

Need a ruling analysed for your business?

Our team tracks all OIDAR developments and can advise on how they affect your specific situation.

Get a ruling reviewed →