2025-VIL-104-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR - Job Work Services, Cutting of Metallic Film Rolls, Textile Processing – Applicable GST rate and classification for job work services involving cutting of metallic film rolls used in manufacturing zari/metallic yarn for sarees – Whether the activity qualifies for 5% rate under Serial No. 26(i)(b) of Notification No. 11/2017-CT(Rate) for textile and textile products falling under Chapters 50-63 of Customs Tariff Act 1975, or 12% rate under Serial No. 26(id) for general job work services, or 18% rate under Serial No. 26(iv) for manufacturing services on physical inputs owned by others – HELD – The Serial No. 26(i)(b) to Notification No. 11/2017-CT(R) provides 5% GST rate only for job work "in relation to textiles and textile products falling under chapters 50 to 63" of the Customs Tariff Act, 1975. However, the applicant failed to establish that metallic film rolls supplied by the principal fall under the category of textiles and textile products covered by chapters 50-63, as the HSN code of metallic film rolls was not mentioned in the delivery challan, and no evidence was provided to demonstrate that these rolls qualify as textile products under the specified chapters - The 18% GST rate under Serial No. 26(iv) covers only services on physical inputs owned by persons other than those registered under CGST Act, whereas in this case, the applicant's clients are registered persons under GST. Therefore, the job work activity falls within the ambit of Serial No. 26(id) which covers "services by way of job work other than those mentioned at serial Nos. 26(i), (ia), (ib), (ic) & (ica)" and attracts 12% GST rate - the applicable GST rate for job work involving cutting of metallic film rolls is 12% under Serial No. 26(id) of Notification No. 11/2017-CT(Rate) – Ordered accordingly
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