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Microlesson · 5-min read

Supply between Association/Club and its Members - Section 7(1)(aa)

# Section 7(1)(aa): Supply between Association/Club and its Members

## The Provision

Any activity or transaction involving supply of goods or services:

  • Between a person OTHER THAN AN INDIVIDUAL (e.g., association, club, society) AND its members or constituents, or vice versa
  • For cash, deferred payment or other valuable consideration

Is treated as SUPPLY.

## The Explanation — Overriding Doctrine of Mutuality

### What is the Doctrine of Mutuality?

A pre-GST common law doctrine: 'A person cannot make a profit from himself.' Therefore, transactions between a club and its members were treated as transactions with oneself — not commercial supplies.

### How Section 7(1)(aa) Overrides It

The Explanation to Sec 7(1)(aa) deems the association/club and its members as SEPARATE PERSONS, and transactions between them are deemed supply.

The explanation begins with a non-obstante clause, giving overriding effect over:

  • Any existing law
  • Any court judgment
  • Any order

that would otherwise apply the doctrine of mutuality.

### Important — Retrospective Intent

This provision was inserted to overcome the Supreme Court's ruling in Calcutta Club Ltd. case, ensuring clubs/associations are taxable on transactions with members.

## Practical Examples

TransactionTreatment
RWA supplies air-conditioners to members at concessional ratesSUPPLY
RWA collects maintenance charges from membersSUPPLY
Gymkhana club provides golf access for member feesSUPPLY
Trade association charges annual membership subscriptionSUPPLY

## Why 'Other than an Individual'?

An individual cannot have 'members' in the legal sense. Section 7(1)(aa) targets:

  • Companies, Firms, HUFs, LLPs, Trusts, Co-operative societies, Clubs/associations

## Memorising Anchor

'Club & Member = Distinct Persons under GST' — doctrine of mutuality is dead under GST.

Worked example

### Example 1

Example 1 – RWA maintenance: ABC RWA collects ₹3,000/month per flat from 50 flat-owners (total ₹1,50,000/month).

  • RWA and individual flat-owners deemed separate persons
  • Maintenance = SUPPLY
  • GST applies subject to threshold and exemption (currently exemption up to ₹7,500/month per member)

### Example 2

Example 2 – Club concessional sale: Sports club buys tennis rackets at ₹4,000 each, sells to members at ₹3,500.

  • Despite concession, transaction from club → member with valuable consideration
  • Sec 7(1)(aa) applies → SUPPLY

### Example 3

Example 3 – Doctrine of mutuality argument: A taxpayer cites the Calcutta Club Supreme Court decision arguing subscription is not taxable.

  • Non-obstante explanation overrides this jurisprudence
  • Subscription IS taxable under GST

⚠️ Common exam mistakes

  • Applying the doctrine of mutuality — Sec 7(1)(aa) explicitly overrides it
  • Forgetting Sec 7(1)(aa) does not apply to individuals
  • Treating only commercial clubs as covered — even non-commercial RWAs and associations are caught
Bare-Act text Section 7(1)(aa) · CGST Act, 2017 · click to expand
Section 7(1)(aa): the activities or transactions, by a person, other than an individual, to its members or constituents or vice versa, for cash, deferred payment or other valuable consideration. Explanation: notwithstanding anything contained in any other law for the time being in force or any judgment, decree or order of any Court, tribunal or authority, the person and its members or constituents shall be deemed to be two separate persons and the supply of activities or transactions inter se shall be deemed to take place from one such person to another.
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