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2022 (12) TMI 1173 - AAAR - GSTClassification of goods - SAC Code - rate of GST - outward supply - support services - mangroves being cultivated and nurtured at coastal communities - HELD THAT:- It is evident that the appellant is engaged in business of cultivation, planting and nurturing of mangrove seeds and seedlings for the primary purpose of environmental protection by way of enhancing biodiversity and re-establishing the ecosystem functions and such services are not related to cultivation of plants for food, fibre, fuel, raw material or other similar products. Therefore, none of the activities carried out by the appellant for the purpose as laid down in the agreement qualifies to be agriculture as claimed by him which is essential to be classified under SAC 9986. The services rendered by the appellant can be classified as ‘Other environmental protection services’ and not as ‘Support services to agriculture, forestry, fishing, animal husbandry’ - there are no infirmity in the ruling pronounced by the WBAAR being that the supply of services for plantation of mangrove seeds and seedlings in coastal areas shall be covered under Serial Number 32 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017 having SAC 9994 and shall attract GST @ 18%.
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