Service by way of drilling of Borewells for supply of water in agricultural land and Letting out of compressors for pumping of water from the borewells to the agricultural field are not ‘Support Service for agriculture, and therefore the exemption is not applicable to the above activities
Classification of supply— In the instant case, applicant has sought Advance Ruling on the following questions:
1. Whether the following supply of services provided by the applicant are in relation to agricultural operations directly in connection with raising of agricultural produce:
i. Drilling of Borewells for supply of water for agricultural operations like cultivation including seeding, planting and ploughing.
ii. Letting out of compressors for pumping of water from the borewells to the agricultural fields.
2. If the answer to the above question is in the affirmative, whether the said services are covered by the entry SI.No 54 of Notification 12/2017 CT(Rate) dated 28.06.2017
In the case at hand the applicant does not undertake the ‘operation of irrigation system for agricultural purposes’ and also ‘compressors’ are not agricultural machinery. They undertake the activity of drilling of borewells in the agricultural land and let out compressors. The said activity is not classifiable under SAC 9986. It is pertinent to note that even setting up of an irrigation system with pipe lines are classifiable only under SAC 9983 and the activity of ‘operation’ of such irrigation system alone is coded as ‘Support service to agriculture’.
Held that— Drilling of Borewells for supply of water in agricultural land is not ‘Support Service for agriculture classifiable under ‘SAC 9986’. Letting out of compressors for pumping of water from the borewells to the agricultural field is not ‘Support Service for agriculture classifiable under ‘SAC 9986’.
The above two activities of the applicant are not ‘Support service for agriculture’ classifiable under SAC 9986 and therefore the exemption at SI.No.54 of Notification No.12/2017-C.T.(Rate) is not applicable to the above activities of the applicant.
Service by way of drilling of Borewells for supply of water in agricultural land and Letting out of compressors for pumping of water from the borewells to the agricultural field are not ‘Support Service for agriculture, and therefore the exemption is not applicable to the above activities
Classification of supply— In the instant case, applicant has sought Advance Ruling on the following questions:
1. Whether the following supply of services provided by the applicant are in relation to agricultural operations directly in connection with raising of agricultural produce:
i. Drilling of Borewells for supply of water for agricultural operations like cultivation including seeding, planting and ploughing.
ii. Letting out of compressors for pumping of water from the borewells to the agricultural fields.
2. If the answer to the above question is in the affirmative, whether the said services are covered by the entry SI.No 54 of Notification 12/2017 CT(Rate) dated 28.06.2017
In the case at hand the applicant does not undertake the ‘operation of irrigation system for agricultural purposes’ and also ‘compressors’ are not agricultural machinery. They undertake the activity of drilling of borewells in the agricultural land and let out compressors. The said activity is not classifiable under SAC 9986. It is pertinent to note that even setting up of an irrigation system with pipe lines are classifiable only under SAC 9983 and the activity of ‘operation’ of such irrigation system alone is coded as ‘Support service to agriculture’.
Held that— Drilling of Borewells for supply of water in agricultural land is not ‘Support Service for agriculture classifiable under ‘SAC 9986’. Letting out of compressors for pumping of water from the borewells to the agricultural field is not ‘Support Service for agriculture classifiable under ‘SAC 9986’.
The above two activities of the applicant are not ‘Support service for agriculture’ classifiable under SAC 9986 and therefore the exemption at SI.No.54 of Notification No.12/2017-C.T.(Rate) is not applicable to the above activities of the applicant.