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Microlesson · 5-min read

CBIC Circulars on TOS - HAM Model and Spectrum Usage

# CBIC Circulars on TOS — HAM Model & Spectrum Usage Charges

Two important clarifications from CBIC on TOS for special cases:

## 1. TOS Under HAM (Hybrid Annuity Model) Contracts

HAM is a model used in National Highway construction where:

  • Part of the contract value is paid during construction (40%);
  • The remaining (60%) is paid as deferred annuities along with interest over the operations period.

TOS treatment: HAM contracts are treated as a continuous supply of service — TOS is the date of completion of the milestone event (each annuity is linked to an event). Interest component is treated as part of value of supply since it forms consideration for deferred payment.

## 2. TOS for Spectrum Usage Services & Similar Services (Natural Resource Allocation)

For allocation of natural resources (e.g., spectrum, mining rights) where the licence fee is payable in installments over a period:

TOS = Need-to-pay basis — i.e., TOS arises as and when payment is due under the contract, even if actual payment is delayed. Each installment is a separate TOS event.

## Why These Circulars Matter

These are special long-tenure arrangements where applying the standard 30-day-from-supply or payment trigger would be impractical. The Government has clarified milestone/installment-based TOS to align with commercial reality.

Worked example

### Example 1

Example 1 — HAM: Highway contractor reaches construction milestone on 1 Sept; annuity installment due 30 Sept. TOS = 1 Sept (date of completion of the milestone event) for both construction value and interest portion attributable to that milestone.

### Example 2

Example 2 — Spectrum: Telecom operator wins spectrum auction; installment of ₹500 cr due on 30 April every year for 5 years. TOS for FY1 installment = 30 April of FY1, regardless of actual payment date.

⚠️ Common exam mistakes

  • Treating HAM annuities as exempt 'deferred payment' — the interest portion is taxable as part of value of supply.
  • Applying the standard 30-day invoice rule to spectrum installments instead of the 'as and when due' clarification.
  • Forgetting that each annuity/installment is its OWN TOS event — not aggregating them into one supply.
Reference: — CBIC Circulars on GST (HAM Model & Spectrum Usage Services)
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