2025-VIL-56-AAR

SGST Advance Ruling Authority

GST – Rajasthan AAR - Section 2(68) of the CGST Act, 2017 - Job work, Composite supply, Principal supply, Classification - Applicant is engaged in the business of supplying job work services towards fabrication and attachment of Body of commercial vehicles and carriers - Applicant receives the unfinished vehicle (consisting of chassis, engine, wheels, etc.) from its customer on free of cost basis and fabricates the tipper body and attaches it to the chassis using its own labor and machinery - Whether the activity undertaken by the Applicant would qualify as 'job work' as per the provisions of Section 2(68) of the CGST Act – Difference of Opinion – HELD – Per Member (Central Tax): the process undertaken by the applicant amounts to job work and fit for classifiable under ‘supply of services’ - the services of fabrication of body on chassis provided by their customer is rightly covered under Heading 9988 [Manufacturing services on physical inputs owned by others], which attracts tax rate of 18% - Per Member (State Tax): the activity of fabrication of tipper body by the applicant on the chassis provided by the customer is a composite supply. The principal supply of goods i.e. tipper body is classifiable under chapter heading 8707 attracting 28% tax rate - Since both members of Advance Ruling Authority have divergent views on the application, the matter is referred to Appellate Authority, Jaipur in terms of Section 98(5) of the CGST Act, 2017 – Ordered accordingly

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