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Transport of the inputs from principal for processing through pipe lines to the premises of job worker as well as return of processed goods after job work to the principal can’t be treated as taxable supply.

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Section 143 of the CGST Act, 2017— Job-Work– The applicant is a Public sector undertaking operating oil refinery and producers of several petroleum products. The applicant requires industrial Gases such as Hydrogen, Nitrogen and Steam, which are obtained from inputs such us ‘Re-gasified Liquefied Natural Gas (RLNG). The applicant permitted one firm to put up a facility for processing of industrial gases on Build Own Operate basis. The applicant transports the inputs for processing through pipe lines to that firm. The applicant proposed to execute job work agreement with that firm for producing the industrial gases using the inputs provided by the applicant and send hack the processed industrial gas to him. The applicant sought for advance ruling as to (i) whether Re-gasified Liquefied Natural Gas (RLNG), de-mineralized water (DM Water), Hydrogen Rich off Gas and raw water etc can be sent by the applicant to that firm without payment of GST under the job work provisions in terms of Section 143 of GST (ii) whether Hydrogen, Nitrogen and Steam (Industrial Gases) can be bought back by the applicant from that firm without payment of GST under the job work provisions in terms of Section 143 of GST.
Held that:- The Hon’ble Authority for Advance Ruling held that the activity of the applicant of sending inputs free of cost to that firm for manufacture of Hydrogen, Nitrogen and Steam, amount to job work under the provisions of Section 143 of the Act.Bharat Petroleum Corporation Limited [2018] 5 TAXLOK.COM 68 (AAR-Kerala)

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