Text
The text below is the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.[1] The Act as published in the Gazette of India is the legal source.
Schedule III, verbatim (show)
SCHEDULE III.
[ See section 7 ]
ACTIVITIES OR TRANSACTIONS WHICH SHALL BE TREATED NEITHER AS A SUPPLY OF GOODS NOR A SUPPLY OF SERVICES
1. Services by an employee to the employer in the course of or in relation to his employment.
2. Services by any court or Tribunal established under any law for the time being in force.
3.
(a) the functions performed by the Members of Parliament, Members of State Legislature, Members of Panchayats, Members of Municipalities and Members of other local authorities;
(b) the duties performed by any person who holds any post in pursuance of the provisions of the Constitution in that capacity; or
(c) the duties performed by any person as a Chairperson or a Member or a Director in a body established by the Central Government or a State Government or local authority and who is not deemed as an employee before the commencement of this clause.
4. Services of funeral, burial, crematorium or mortuary including transportation of the deceased.
5. Sale of land and, subject to clause (b) of paragraph 5 of Schedule II, sale of building.
6. Actionable claims, other than 3[Specified actionable claims].
*7. 1[Supply of goods from a place in the non-taxable territory to another place in the non-taxable territory without such goods entering into India.
*8.
(a) Supply of warehoused goods to any person before clearance for home consumption;
5[(aa) Supply of goods warehoused in a Special Economic Zone or in a Free Trade Warehousing Zone to any person before clearance for exports or to the Domestic Tariff Area;]
(b) Supply of goods by the consignee to any other person, by endorsement of documents of title to the goods, after the goods have been dispatched from the port of origin located outside India but before clearance for home consumption.]
4[9. Activity of apportionment of co-insurance premium by the lead insurer to the co-insurer for the insurance services jointly supplied by the lead insurer and the co-insurer to the insured in co-insurance agreements, subject to the condition that the lead insurer pays the central tax, the State tax, the Union territory tax and the integrated tax on the entire amount of premium paid by the insured.
10. Services by insurer to the reinsurer for which ceding commission or the reinsurance commission is deducted from reinsurance premium paid by the insurer to the reinsurer, subject to the condition that the central tax, the State tax, the Union territory tax and the integrated tax is paid by the reinsurer on the gross reinsurance premium payable by the insurer to the reinsurer, inclusive of the said ceding commission or the reinsurance commission.]
2[Explanation 1.-For the purposes of paragraph 2, the term "court" includes District Court, High Court and Supreme Court.
*1[Explanation 2.- For the purposes of 5[clause (a) of] paragraph 8, the expression "warehoused goods" shall have the same meaning as assigned to it in the Customs Act, 1962 (50 of 1962).]
5[Explanation 3.]––For the purposes of clause (aa) of paragraph 8, the expressions “Special Economic Zone”, “Free Trade Warehousing Zone” and “Domestic Tariff Area” shall have the same meanings respectively as assigned to them in section 2 of the Special Economic Zones Act, 2005.
* Retrospective exemption to certain activities and transactions vide s. 159 of The Finance Act 2023 (No. 8 of 2023). Brought into force w.e.f. 01st July, 2017.
1. Inserted by s.32 of The Central Goods and Services Tax (Amendment) Act, 2018 (No. 31 of 2018) - Brought into force w.e.f. 01st February, 2019.
2. Re-numbered by s.32 of The Central Goods and Services Tax (Amendment) Act, 2018 (No. 31 of 2018) - Brought into force w.e.f. 01st February, 2019.
3. Substitued by s.4 of The Central Goods and Services Tax (Amendment) Act, 2023 (No. 30 of 2023) - w.e.f. 01.10.2023.
4. Inserted by section 149 of The Finance Act (No. 2) Act, 2024 No. 15 of 2024 dated 16.08.2024.
5. Inserted (w.e.f. 01.10.2025) by section 133 of the Finance (No. 7) Act, 2025.
Questions to answer on the file
Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.
Scope of the Schedule the rubric, the heading and the date of the activity
Questions to answer on the file2 questions
Services by an employee to the employer paragraph 1
Questions to answer on the file4 questions
Services by a court or Tribunal paragraph 2 with Explanation 1
Questions to answer on the file3 questions
Functions and duties of holders of public office paragraph 3, clauses (a), (b) and (c)
Questions to answer on the file9 questions
Funeral, burial, crematorium and mortuary services paragraph 4
Questions to answer on the file2 questions
Sale of land and sale of building paragraph 5, with clause (b) of paragraph 5 of Schedule II
Questions to answer on the file4 questions
Actionable claims other than specified actionable claims paragraph 6
Questions to answer on the file2 questions
Goods moved between two places in the non-taxable territory paragraph 7
Questions to answer on the file4 questions
Goods supplied before clearance paragraph 8, clauses (a), (aa) and (b), with Explanations 2 and 3
Questions to answer on the file10 questions
Apportionment of co-insurance premium paragraph 9
Questions to answer on the file5 questions
Ceding commission on reinsurance paragraph 10
Questions to answer on the file4 questions
Amendment history
The CBIC text carries 4 footnotes. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]
| Note | Change |
|---|---|
| 1 | Inserted by s.32 of The Central Goods and Services Tax (Amendment) Act, 2018 (No. 31 of 2018) - Brought into force w.e.f. 01st February, 2019.[2] |
| 2 | Re-numbered by s.32 of The Central Goods and Services Tax (Amendment) Act, 2018 (No. 31 of 2018) - Brought into force w.e.f. 01st February, 2019.[2] |
| 4 | Inserted by section 149 of The Finance Act (No. 2) Act, 2024 No. 15 of 2024 dated 16.08.2024.[3] |
| 5 | Inserted (w.e.f. 01.10.2025) by section 133 of the Finance (No. 7) Act, 2025.[4] |
Relationship with other provisions
| Provision | Connection | Words that tie them |
|---|---|---|
| Section 7 | Section 7 requires this provision | 7(2)(a) "activities or transactions specified in Schedule III"; the Schedule's rubric "[ See section 7 ]" |
| Section 7 | 7(1) of Section 7 overridden by this provision | 7(2) "Notwithstanding anything contained in sub-section (1)" |
| Schedule II | paragraph 5 requires Schedule II | paragraph 5 "subject to clause (b) of paragraph 5 of Schedule II" |
| Schedule II | paragraph 5 requires Schedule II | |
| Schedule II | paragraph 5 requires Schedule II | |
| Schedule II | paragraph 5 requires Schedule II | |
| Section 2 | paragraph 6 defined by Section 2 clause (102A) | paragraph 6 "Actionable claims, other than 3[Specified actionable claims]"; 2(102A) "specified actionable claim" means the actionable claim involved in or by way of" |
| Section 2 | paragraph 7 defined by Section 2 clause (79) | paragraph 7 "a place in the non-taxable territory"; 2(79) "non-taxable territory" means the territory which is outside the taxable territory" |
| Section 17 | Section 17 requires this provision | Explanation to 17(3) "shall not include the value of activities or transactions specified in Schedule III" |
Circulars and notifications
Circulars and notifications in the CBIC repository that cite this section, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.
Circulars (10)
| Number | Date | Subject |
|---|---|---|
| Circular No. 244/01/2025-GST | 28 January 2025 | Regularizing payment of GST on co-insurance premium apportioned by the lead insurer to the co-insurer and on ceding /re-insurance commission deducted from the reinsurance premium paid by the insurer to the reinsurer. |
| Circular No. 243/37/2024-GST | 31 December 2024 | Clarification on various issues pertaining to GST treatment of vouchers |
| Circular No. 213/07/2024-GST | 26 June 2024 | Seeking clarity on taxability of re-imbursement of securities/shares as SOP/ESPP/RSU provided by a company to its employees. |
| Circular No. 177/09/2022-GST | 3 August 2022 | Clarifications regarding applicable GST rates & exemptions on certain services |
| Circular No. 172/04/2022-GST | 6 July 2022 | Clarification on various issue pertaining to GST |
| Circular No. 140/10/2020-GST | 10 June 2020 | Clarification in respect of levy of GST on Director's Remuneration. |
| Circular No. 113/32/2019-GST | 11 October 2019 | Clarification regarding GST rates & classification (goods) Circular-reg. |
| Circular No. 4/01/2019-IGST | 1 February 2019 | Seeks to make amendments in the earlier issued circulars in wake of amendments in the CGST Act, 2017 (which shall come into force w.e.f. 01.02.2019). |
| Circular No. 46/20/2018-GST | 6 June 2018 | Applicable GST rate on Priority Sector Lending Certificates (PSLCs), Renewable Energy Certificates (RECs) and other similar scrips -regarding. |
| Circular No. 44/18/2018-GST | 2 May 2018 | Issue related to taxability of 'tenancy rights' under GST- Regarding. |
Notifications (6)
| Number | Date | Subject |
|---|---|---|
| Notification No. 38/2023-Central Tax | 4 August 2023 | Seeks to make amendments (Second Amendment , 2023) to the CGST Rules, 2017. |
| Notification No. 12/2018-Central Tax | 7 March 2018 | Second Amendment (2018) to CGST Rules |
| Notification No. 03/2018-Central Tax | 23 January 2018 | First Amendment 2018, to CGST Rules |
| Notification No. 24/2017-Central Tax (Rate) | 21 September 2017 | Seeks to amend notification No. 11/2017-CT(R) to reduce CGST rate on specified supplies of Works Contract Services. |
| Notification No. 24/2017-Integrated Tax (Rate) | 21 September 2017 | Seeks to amend notification No. 08/2017-IT(R) to reduce CGST rate on specified supplies of Works Contract Services. |
| Notification No. 24/2017-Union Territory Tax (Rate) | 21 September 2017 | Seeks to amend notification No. 11/2017- UTT(R) to reduce CGST rate on specified supplies of Works Contract Services. |
Unsettled questions
The words of schedule iii do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.
- How close must the connection between a service and the employment be before it is supplied "in the course of or in relation to his employment"? Paragraph 1 uses two different connectors and defines neither, and nothing in the Act says whether a recovery an employer makes from an employee, or a benefit given outside the contract of employment, is within them.
- What is it to have been "deemed as an employee before the commencement of this clause"? Clause (c) makes the whole exclusion turn on a deeming, and neither the clause nor the Act says under what law the person is deemed an employee, or on what date the clause commenced for this purpose.
- What makes a transfer of immovable property a "sale" for paragraph 5? The paragraph excludes sale of land and sale of building and the Act defines neither "sale" nor "land", so nothing in the text says whether a transfer of development rights, a long lease or an agreement to sell falls inside the word.
- As at what moment is a "subject to the condition that... tax is paid" requirement tested, and what follows where the tax is paid late or in part? Paragraphs 9 and 10 each attach the exclusion to a payment by another person and neither fixes a date by which that payment must be made, nor says what happens to an apportionment or a service already made when the payment is later short.
See also
- Section 7 of the CGST Act, 2017: scope of supply
- Section 2 of the CGST Act, 2017: definitions
- Section 17 of the CGST Act, 2017: apportionment of credit and blocked credits
- Schedule II of the CGST Act, 2017: activities or transactions to be treated as supply of goods or supply of services
References
- Central Board of Indirect Taxes and Customs. "Schedule III. Activities which shall be treated neither as a supply of goods nor a supply of services". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 4. Retrieved 17 September 2026.
- The Central Goods and Services Tax (Amendment) Act, 2018. Cited in CBIC footnotes 1 and 2.
- The Finance Act (No. 2) Act, 2024. Cited in CBIC footnote 4.
- The Finance (No. 7) Act, 2025. Cited in CBIC footnote 5.
External links
- CGST Act, 2017, Schedule III on the CBIC tax information portal