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GST – Gujarat AAR - Classification of service of semen sorting - The applicant view is that the activities undertaken by them would fall under either SAC 9986 as support services or SAC 998612 as Animal Husbandry services, more specifically SAC 9986, whereas the Department is of the view that it would fall under SAC 998399 - HELD - The applicant's services fall under Heading 9986 of the GST Services Tariff, which covers "Support services to agriculture, forestry, fishing, animal husbandry", and specifically the sub-item (iii) which provides exemption for "Carrying out an intermediate production process as job work in relation to cultivation of plants and rearing of all life forms of animals, except the rearing of horses, for food, fibre, fuel, raw material or other similar products or agricultural produce" - The applicant's semen sorting services are a specialized component of the artificial insemination process for bovine cattle, which is a crucial support service for animal husbandry - The definition of “job work” does not restrict the scope of work to purely labour-intensive tasks. There is no language suggesting that specialized or technical processes are excluded from this definition. Therefore, an activity qualifies as job work regardless of whether it involves manual labour or highly specialized technical procedures. The services qualify as job work under the CGST Act, as the applicant is undertaking processing of semen belonging to the Semen Stations. The legislative intent is to exempt any activity related to the artificial insemination of livestock from GST. Therefore, the "Semen Sorting Services" provided by the applicant are exempt from GST and classified under SAC 9986 – Ordered accordingly
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