Exemptions in Transportation of Goods: Entries 18 to 23

Exemptions in Transportation explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

The structure here is the reverse of most exemptions. Transporting goods by road is exempt as a rule, and the entry then names the two exceptions. Everything else in the group is a targeted carve-out from those exceptions.

Entry 18 exempts transportation of goods (a) by road except by a goods transport agency or a courier agency, and (b) by inland waterways. Entry 19 exempts inbound air freight up to the customs station; entries 19A and 19B exempted outbound air and vessel freight but "shall not apply after the 30th day of September, 2022." Entry 20 exempts rail or vessel carriage of seven categories of goods within India; entry 21 exempts a GTA carrying the same categories; entry 21A exempts a GTA supplying unregistered persons; entry 21B exempts a GTA supplying TDS-only registrants. Entry 23 exempts access to a road or bridge on payment of toll.

Entry 18: the two exceptions that define the sector

"Service of transportation of goods by road is exempt from tax except when provided by — Goods Transport Agency (GTA) Courier Agency."

A GTA is defined by the consignment note. "A 'goods transport agency' has been defined to mean a person who provides service in relation to transport of goods by road and issues consignment note, by whatever name called. Thus, any person who transports goods by road without issuing a consignment note shall not fall within the ambit of GTA and shall be exempt."

A courier agency is "a person engaged in the door-to-door transportation of time-sensitive documents, goods or articles utilising the services of a person, either directly or indirectly, to carry or accompany such documents, goods or articles."

The Handbook's example is deliberately homely: "Mr. A provides service of transportation of goods by road and does not issue consignment note, in a horse cart owned by him. This is exempt."

And inland waterways are exempt without qualification. "Inland Waterway" means national waterways under section 2(h) of the Inland Waterways Authority of India Act, 1985, or other waterways on any inland water as defined in section 2(b) of the Inland Vessels Act, 1917.

The truck operator question, unsettled

The Handbook records a genuine conflict rather than papering over it.

The legislative intent. "The speech of the Union Finance Minister when the GTA was brought into tax net, specifically clarified vide Para 149 that the intent was to levy tax on Transport agent and not to tax the truck operators/owners."

The first decision agreed. In C.C.E. & C., Guntur v. Kanaka Durga Agro Oil Products Pvt. Ltd. 2009 (15) S.T.R. 399 (Tri. - Bang.) it was held that "Service tax paid for services of individual truck operators is not liable on the basis of clarification given by Finance Minister and interpretation of the definition 'agent'." But "this judgement did not discuss the concept of 'any person' in the definition of 'Goods Transport Agency'."

The second disagreed. In C.C.E., Salem v. Subramania Siva Co-Op. Sugar Mills Ltd. (2014) 35 S.T.R. 500 (Mad.) the Madras High Court held that "'any person' would cover all kinds of persons which also covers individual truck owners", and that "speech of Finance Minister cannot be taken in aid for understanding the scope of the clear terms of the provisions."

The Handbook's conclusion is honest: "the issue whether truck owners or operators (in case they issue a consignment note) would attract levy of GST for transportation of goods by road, is open to question."

In practice, the consignment note remains the test. "A single truck owner-operator… the aggregate value of service provided by him exceeded twenty lakh rupees during a financial year. The truck owner is not liable to registration, as services provided by way of transportation of goods by road are exempt."

The specified-goods entries: 20 and 21

Entry 20 — by rail or vessel from one place in India to another: (a) relief materials for victims of natural or man-made disasters, calamities, accidents or mishaps; (b) defence or military equipment; (c) newspapers or magazines registered with the Registrar of Newspapers; (d) omitted — "railway equipments or materials, omitted vide Notification No. 4/2022-CT(R), w.e.f. 18-Jul-2022"; (e) agricultural produce; (f) milk, salt and food grain including flours, pulses and rice; (g) organic manure.

Entry 21 — by a GTA in a goods carriage: the same list, minus railway equipment, and minus the two value limbs. Clauses (b) and (c) — "consideration… on a consignment transported in a single carriage does not exceed one thousand five hundred rupees" and "for a single consignee does not exceed seven hundred and fifty rupees" — were both omitted by Notification No. 4/2022-CT(R) w.e.f. 18.07.2022.

Any freight policy still applying a ₹750 or ₹1,500 threshold is four years out of date.

Entries 21A and 21B: who the GTA supplies

Entry 21A exempts a GTA supplying an unregistered person, including an unregistered casual taxable person, other than six categories: a registered factory, a registered society, a co-operative society, a body corporate, a partnership firm or AOP, or a registered casual taxable person.

The Handbook explains the history: "Prior to 13-Oct-2017, GTAs were liable to pay GST on the service provided to unregistered persons. This was creating lot of workload and inconvenience to GTAs. Therefore, exemption was given."

Entry 21B exempts a GTA supplying a Department or Establishment of the Central or State Government or a Union territory, a local authority, or a Governmental agency, which has taken registration only for the purpose of deducting tax under section 51 and not for making taxable supply.

Both entries pair with the reverse charge notification. The same categories are excluded from entry 1 of Notification No. 13/2017-CT(R), so the recipient neither pays under RCM nor bears forward charge. The GTA reverse charge entry →

And the ancillary-services rule is the same on both sides: intermediary and ancillary services — "loading/unloading, packing/unpacking, transhipment and temporary warehousing" — included in the GTA's invoice form part of the composite GTA service; charged separately, whether on the same invoice or a different one, "they shall be treated as separate supplies."

Air and sea, in and out

Entry 19 — inbound air freight. Transportation of goods by aircraft from a place outside India up to the customs station of clearance in India. "Customs station" takes its meaning from section 2(13) of the Customs Act, 1962. The Handbook's example: "X Ltd. imported goods from Russia and paid air freight for transportation of goods by aircraft till custom clearance in India. Such services are exempt."

Entries 19A and 19B — outbound, and expired. Introduced by Notification No. 2/2018-CT(R) dated 25.01.2018 for air (19A) and vessel (19B) freight from the customs station of clearance in India to a place outside India, both carrying the condition: "Nothing contained in this serial number shall apply after the 30th day of September, 2022."

Note the asymmetry that leaves. Inbound air freight is exempt without a sunset; outbound air and sea freight exemptions lapsed.

Entry 23, and the annuity entry that went

Entry 23 — "Service by way of access to a road or a bridge on payment of toll charges." The Handbook explains the model: "In BOT (Toll) projects, part of the cost is borne by a private person. NHAI collects toll for the usage of road or bridge."

Entry 23A — withdrawn. Access to a road or bridge on payment of annuity was exempt; the entry was "withdrawn vide Notification No. 15/2022-CT(R), dated 30-Dec-2022, w.e.f. 01-Jan-2023." In BOT (Annuity) projects "all the costs are borne by the Government in the form of deferred budgetary payments."

And even before the withdrawal, the annuity for construction was never exempt. Circular No. 150/06/2021-GST dated 17.06.2021 clarified that "Entry 23A… does not exempt GST on the annuity (deferred payments) paid for construction of roads."

Entry 9B completes the group: supply of services associated with transit cargo to Nepal and Bhutan — landlocked countries.

Key takeaways

• Road transport of goods is exempt except by a GTA or a courier agency — and a GTA is defined by the consignment note.
• A transporter issuing no consignment note is exempt, regardless of turnover.
• Whether an individual truck owner who does issue a note is a GTA remains open — Kanaka Durga against Subramania Siva.
• Inland waterways are exempt without qualification.
• Entries 20 and 21 exempt seven categories of goods by rail or vessel and by GTA; railway equipment was omitted on 18.07.2022.
• The ₹750 and ₹1,500 GTA value exemptions were omitted on 18.07.2022.
• Entry 21A exempts GTA supplies to unregistered persons outside six categories; entry 21B to TDS-only government registrants.
• Inbound air freight (entry 19) is exempt; outbound air and vessel freight (19A, 19B) lapsed after 30.09.2022.
• Tolls are exempt (entry 23); the annuity entry 23A was withdrawn from 01.01.2023, and never covered construction annuities.

Read next

• Exemptions in Transportation of Passengers: Entries 15 and 17
• RCM Entry 1: Who Actually Pays GST on a GTA Freight Bill
• Agriculture Exemptions: Entries 54 to 58 and "Agricultural Produce"

Disclaimer: Positions stated as on 5 September 2026, based on entries 9B, 18, 19, 19A, 19B, 20, 21, 21A, 21B, 23 and 23A of Notification No. 12/2017-Central Tax (Rate), Notification Nos. 2/2018, 4/2022 and 15/2022-Central Tax (Rate), Circular No. 150/06/2021-GST, and the decisions in C.C.E. & C., Guntur v. Kanaka Durga Agro Oil Products and C.C.E., Salem v. Subramania Siva Co-Op. Sugar Mills, as reproduced in the ICAI Handbook on Exempted Supplies under GST (April 2025).