Our work · Strategic regulatory & fiscal policy
Connecting legal interpretation, platform architecture, public finance and the wider interests of India’s mobility and gig economy.
Ongoing policy engagement — clarification soughtThe mandate
TLGS is undertaking a substantial strategic regulatory and fiscal-policy mandate concerning the treatment of passenger-transport services facilitated through electronic commerce operators. The engagement brings together technical tax analysis, product and contractual evidence, policy drafting, and coordinated engagement with Union and State institutional processes.
The central question is when an underlying ride is supplied “through” an ECO, rather than merely discovered through a digital interface. The representation seeks a uniform, administrable interpretation that distinguishes material economic intermediation from genuinely limited digital facilitation.
TLGS work products & execution
The work is more than a request letter. It integrates the legal route, factual boundary, fiscal safeguards and government-facing explanation into one structured engagement.
Reading the statutory trigger alongside the relevant notification, the Council record, advance rulings and judicial principles. The work distinguishes the scope of an interpretative clarification from a legislative amendment.
Examining contracts, fund flows and actual platform functions rather than relying on labels such as SaaS, subscription or commission. The framework asks who controls the economics and performance of the underlying ride.
Developing the supplemental representation and a proposed Section 168 clarification, with cumulative conditions, evidence requirements and a defined passenger-mobility scope.
Coordinating a technical policy case for consideration through the relevant Union-government, GST Council and State-government channels. National consistency is considered alongside the concerns of tax administrations and individual States.
Preparing the government presentation, oral-submission structure, research companion and consistent briefing material. Complex legal, product and fiscal questions are organised into a coherent decision request.
Designing auditable eligibility, product separation, change controls and disqualifying conduct. The analysis preserves the separate tax treatment of platform services and addresses revenue concerns without promising zero fiscal impact.
The clarification sought
The proposal requests an interpretative clarification under Section 168. It does not seek an amendment to Section 9(5), a change to the notification, a tax waiver or a company-specific exemption. Its immediate scope is passenger mobility.
Who bindingly determines or enforces the fare?
Who collects or settles the ride consideration?
Who funds ride-linked discounts or incentives?
Who compels acceptance or controls service performance?
Who invoices the ride or presents itself as the transport supplier?
Who assumes responsibility for or commercially underwrites the transport service?
These are the lenses in the proposed cumulative assessment—not a legal safe harbour already available to an operator. The relevant product, contracts, fund flows and actual conduct require separate verification.
A separately taxable platform-service fee, pass or charge independent of the underlying ride fare. No charging formula or methodology is prescribed in this public account.
The proposal distinguishes statutory or regulatory retention and sharing of information from its use to control price, settlement, acceptance, performance or transport-service risk.
Federal policy & administration
The representation links the issue to the continuing examination referenced under Agenda Item 3(iv) of the 55th GST Council meeting. TLGS’s work includes supplemental drafting, technical briefing and a consistent explanation of the proposed boundary for relevant Union and State consideration.
The policy case addresses the concerns of the tax administration as well as business: a workable evidentiary standard, safeguards against relabelling, product-level separation and review when functions change. Correspondence seeking meetings or consideration is not presented here as confirmation that a meeting occurred, the proposal entered a later agenda or relief was approved.
Why the issue matters
The proposal considers provider autonomy, direct passenger-to-provider payment and potential retention of a greater share of ride consideration. These are policy objectives, not measured outcomes of this engagement.
Consumer choice, transparent dealings and the scope for differentiated mobility services are assessed alongside the continuing need for safety and statutory compliance.
A model-neutral boundary could support genuine technology-only innovation, including regional and Tier-2 / Tier-3 business models, without automatically treating every software interface as the underlying service supplier.
Uniform interpretation, auditability and protection against relabelling are integral to the proposal. The platform’s own separately taxable service remains distinct from the underlying ride.
Potential public benefits depend on the qualifying operating model and any eventual official decision. This page does not quantify driver-income gains, tax savings, fiscal impact or an outcome achieved by TLGS.
TLGS expertise
Former Director General (Administration), Indian Air Force; former Member, Armed Forces Tribunal
Director & Executive President
Policy, Regulatory, Legal, Strategic Affairs & Institutional Relations
Decorated Indian Air Force leader with experience across defence administration, military justice, aviation and institutional governance.
View profileFormer Additional Chief Secretary, Government of Odisha; former Adviser, NITI Aayog
Distinguished Policy Principal
Public Policy, Infrastructure, Institutional Governance & Regulatory Strategy
Former Additional Chief Secretary, Government of Odisha, and former Adviser, NITI Aayog, with a public-policy and infrastructure background.
View profileFormer Principal Chief Commissioner, Customs & CGSTIRS (C&IT), 1989 batch · Former Technical Member, National Anti-Profiteering Authority
Principal GST Technical Advisor
GST, Indirect Tax & Fiscal Policy
Former Principal Chief Commissioner, Customs & CGST; IRS (C&IT), 1989 batch. His experience spans tax administration, GST intelligence, anti-profiteering and capacity building.
View profileFormer Judge
Director & Group Principal
Collaborations & Strategic Growth
Former Judge with multidisciplinary experience across international trade, infrastructure and EPC, public procurement, regulatory strategy and enterprise growth. Leads TLGS’s collaborations and strategic-growth remit.
View profilePractice Principal
Tax, Finance, Regulatory & Strategic Advisory
New Delhi-based Chartered Accountant and Practice Principal, connecting tax and financial review with regulatory analysis, policy coordination and practical support for client mandates.
View profileBoard Affairs & Strategic Communication Lead
MD Office
Company Secretary with experience in corporate law, board affairs, FEMA, secretarial compliance and strategic communication.
View profileSelected relevant TLGS professionals. Engagement responsibilities and participation are coordinated according to scope, subject matter and availability; this listing is not a record of attendance at a government meeting.
Bharat Pulse · TLGS policy perspective
Why the proposed assessment focuses on actual platform functions, not a business label—and why passenger mobility must be analysed on its own facts.
Published 13 September 2026 · Explains an ongoing TLGS proposal. Not a notification, tax exemption or report of government acceptance.
The description of TLGS’s work and the proposed framework is drawn from its engagement materials. Public sources identify the legal and historical context; they do not endorse TLGS or its proposal. Internal research, correspondence and product-specific material are not reproduced.
Public overview reviewed 13 September 2026. Client identity, commercial terms, internal strategy and confidential work products are not disclosed.
Start with the policy problem
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