2026-VIL-156-AAR
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SGST Advance Ruling Authority

GST – Tamil Nadu AAR - Classification of semen sorting services under appropriate service code - Determination of eligibility for exemption as support services to agriculture under GST - Applicant separates X and Y chromosome bearing cells from bovine semen using proprietary technology and provides services to semen stations managing bull farms - Raw semen is received from semen station, processed using technology, and unpacked processed material returned for further processing and packing into semen straws used for artificial insemination - Whether semen sorting services are classifiable under SAC code 9986 as support services to agriculture qualifying for exemption and what is appropriate classification - HELD - Semen sorting services are not classifiable under SAC 9986 (Support services to agriculture, hunting, forestry, fishing) as they do not fall within definition of support services to agriculture or intermediate production process relating to rearing of life forms for food, fibre, fuel or raw material - Services are technology-driven laboratory-based processing and separation service performed on biological material constituting value-addition and testing service independent of actual rearing, feeding, breeding management or husbandry of livestock - Services are appropriately classifiable under SAC 998349 (Other technical and scientific services nowhere else classified) as specialized technical and scientific services - Under Notification 11/2017-Central Tax (Rate) dated 28.06.2017, services falling under HSN 9983 and liable to GST rate of 18 percent - Semen sorting services are not exempt from GST and attract GST rate of 18 percent under SAC 998349 - Ordered accordingly
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