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Microlesson · 5-min read

Para 5(e) of Schedule II – Agreeing to refrain/tolerate/do an act

# Para 5(e) of Schedule II – Obligation to Refrain, Tolerate, or Do an Act

Para 5(e) of Schedule II declares certain obligations as a supply of services. It has three limbs:

## Three Limbs of Para 5(e)

### 1. Agreeing to refrain from an act

A person agrees NOT to do something in exchange for consideration.

  • Examples: Non-compete agreements; agreeing to limit construction height; halting production temporarily for compensation.

### 2. Agreeing to tolerate an act or situation

A person agrees to PERMIT/PUT UP WITH something for consideration.

  • Examples: Allowing hawkers on the pavement; tolerating loudspeakers from a nearby venue with compensation.

### 3. Agreeing to do an act

A person agrees to perform a specific act (beyond legal obligation) for consideration.

  • Examples: Installing zero-emission equipment voluntarily (no legal mandate) in return for payment.

## Conditions to Qualify under Para 5(e)

For an activity to fall under Para 5(e), BOTH conditions must be satisfied:

### Condition 1: Express or Implied Contract Must Exist

  • The act of refraining/tolerating/doing must be under an agreement or contract (express or implied).
  • One party must be under a contractual obligation to the other.
  • The agreement may be standalone OR part of another contract.
  • Important: A mere flow of money between parties does NOT presume the existence of a contract.

### Condition 2: Consideration Must Flow in Return

  • Some consideration must flow from the other party to the first party in return for refraining/tolerating/doing the act.
  • Without consideration linked to the obligation, there is no supply under Para 5(e).

## Practical Application

If money flows but there is no contractual obligation to refrain/tolerate/do, it is NOT a Para 5(e) supply. Examples: liquidated damages, penalties for breach, forfeiture of earnest money – these are compensation, not consideration for tolerating breach.

Worked example

### Example 1

Example 1 (Non-compete): A Co. pays B Co. ₹10 lakh under a contract requiring B Co. not to start a competing business for 3 years. ✔ Express contract exists; ✔ consideration flows. → Taxable supply of service under Para 5(e) limb (i) – refraining from an act.

### Example 2

Example 2 (Tolerance): A factory pays a neighbouring residential society ₹50,000/month as compensation for tolerating noise/vibration. ✔ Implied/express agreement; ✔ consideration. → Supply of service under limb (ii) – tolerating an act.

### Example 3

Example 3 (Doing an act): A municipality pays a private firm ₹5 lakh to voluntarily install zero-emission equipment (no statutory requirement). → Supply of service under limb (iii) – doing an act.

⚠️ Common exam mistakes

  • Assuming any flow of money between parties automatically creates a Para 5(e) supply. A contract (express/implied) AND consideration both must exist.
  • Treating liquidated damages or penalties for breach as Para 5(e) supplies – these are compensation for loss, not consideration for tolerating breach.
  • Confusing 'doing an act' under Para 5(e) with statutory/legal obligations – Para 5(e) covers only voluntary contractual obligations.
Bare-Act text Schedule II, Para 5(e) · CGST Act, 2017 · click to expand
Para 5(e), Schedule II, CGST Act, 2017: 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.
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