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2019 (11) TMI 1364 - AAR - GSTLevy of GST - rate of GST - Extraction of Timber/ Bamboo in natural Forests - Transportation of Timber/ Bamboo from natural Forests to the Govt. Depots - Maintenance of Govt. Depots like classification/ grading of timber and bamboo and wages to Mastris for supervision - HELD THAT:- What is a support service in relation to the above had been defined by means of an explanation to the same entry. And the explanation had employed the word 'mean' which is restrictive in nature. Thus what is given in explanation shall only mean as support services and nothing else shall. From the explanation given to the entry, the support services mentioned are only in relation to agriculture and fishery and animal husbandry. None of the services are mentioned in relation to natural forests. Moreover, agricultural produce and natural forest produce are entirely different and involve different processes starting form plantation to harvesting - Hence in the absence of any specific exemption to that effect, one cannot extend the services that are mentioned in relation to agriculture to those of natural forests. It is a settled law that an exemption or a relief provided in an enactment shall only be interpreted in the exact wording employed in the legislature. Nothing can be extrapolated or inferred to extend the scope of an exemption. Therefore, the service in question viz., a) cutting logging b) Transportation c) maintenance of depots of forest department cannot be covered under the said entry 24(i) - The transactions referred to are taxable at the rate of 9% CGST + 9% SGST as per the general entry 35 of the notification no 11/2017 dt:28-06-2017.
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