JUDGMENT

The issues raised in this writ petition appear to be covered in favour of the petitioner in the light of clarifications issued vide Circular No.204/16/2023-GST dated 27-10-2023 and also by Circular No.218/12/2024-GST dated 26-06-2024 issued by the GST Policy Wing, Central Board of Indirect Taxes and Customs, Department of Revenue, Ministry of Finance, Government of India. The questions raised are whether any GST is payable on reverse charge basis on supply of services by the Managing Director of the company by way of providing personal guarantee on loans taken by the company and whether any GST is payable on supply of services by way of extending loans by the petitioner-company to its subsidiary company. In Circular No.204/16/2023-GST dated 27-10-2023 it was clarified as follows: