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The work undertaken by the applicant is a ‘Support Service to Mining’, covered under HSN 998622 and attracts GST @ 18%

Classification of service— In the present case, the applicant has been tasked to extract 2 lakh MT of Serpentine/Green Marble per year at M/s. AMP’s Dungarpur mining site located at Simalwara, Rajasthan. In the agreement, the applicant has also been asked to deploy some earthmoving vehicles and manpower at the mining site.
Questions on which advance ruling is sought—
1. Applicability of SAC and Classification of the said work contract in either of the two codes viz. SAC 9973 - Leasing or rental services concerning machinery & equipment with or without operator or SAC 9954 - Composite supply of Work contract services?

2. What is the difference between operator and manpower as per GST Provisions?

3. Whether the Special Purpose Vehicles in the above work order are classified as “Machinery”?

Held that— we find that the applicant is providing supporting service related to mining. The said service is classifiable under HSN 998622. The rate of GST on the said service is 18%.
Question 2 & 3 are beyond the scope of mandate given to this authority as per Section 97 (2) of CGST Act, 2017, therefore, no ruling is given.—Ksc Buildcon Private Limited, In Re… [2020] 24 TAXLOK.COM 042 (AAR-Rajasthan)

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