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The activity of job work consisting of fabrication including of bullet proof work done on chassis provided by the Principal is a supply of Service attracting GST @ 18%.

Classification of supply— In the instant case, applicant is is engaged in the manufacture of Bullet proof glass, bullet proof Vehicles, Lectern etc. in their factory. Besides, applicant is also undertaking armouring by body building on the chassis of vehicles supplied by the customers mainly the army/ police etc. using bullet proof steel and glass. The applicant classifies the work done by it under the “goods” category bearing HSN 87079000 with GST @ 28%. QUESTIONS ON WHICH THE ADVANCE RULING IS SOUGHT— 1. Whether the activity of bullet proof body building (in addition to fixing bullet proof windshield glass, bullet proofing of engine and fuel tank on the motor vehicles (2.5 Ton capacity) of Chapter heading 87 of the Customs Tariff Act, 1975, supplied by the customer (i.e. free supply) having Tarpaulin cover in the cargo compartment, is classifiable as supply of service under service classification head 9988 (ic) or 9988 (id) of the GST tariff attracting CGST and SGST of 9% + 9% / IGST of 18% under the provisions of the CST Act/ IGST Act 2017? 2. Since the applicant has already charged IGST @ 28% by classifying the supply as supply of goods under GST tariff for goods heading 8707, whether the customer should claim the refund from the department or the applicant should lodge the claim the refund, in the event of the above classification being upheld by the AAR? Held that— The activity carried out by the applicant by making bullet proof body building (in addition to fixing bullet proof windshield glass, bullet proofing of engine and fuel tank) on the motor vehicles (2.5 Ton capacity) of Chapter heading 87 of the Customs Tariff Act, 1975, supplied by the customer (i.e. free supply) having Tarpaulin cover in the cargo compartment, is a supply of Service attracting GST 18% Since, the applicant has sought ruling on issue of refund of tax which is outside the purview/scope of this Authority as defined under Section 97(2) of the act ibid.
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