Technical testing of animal feed falls outside GST exemption for animal husbandry support services.

Testing of animal feed, feed ingredients and feed supplements is not covered by the exemption in Notification No. 12/2017-Central Tax (Rate) for services relating to rearing of animals by way of specified agricultural operations. The activity consisted of chemical and biological testing, including analysis of crude protein, fibre, moisture and mycotoxins, and was classified as technical testing and analysis services under Heading 998346 rather than animal husbandry support services under Heading 9986. The exemption was held not to extend to this testing activity because the service did not fall squarely within the exempted description.

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Issues: Whether testing of animal feed, feed ingredients and feed supplements is covered under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 as a service relating to rearing of all life forms of animals by way of testing.

Analysis: The exemption under Sl. No. 54 applies to services relating to cultivation of plants and rearing of all life forms of animals by way of specified agricultural operations directly related to production of agricultural produce, including testing. The activity undertaken by the applicant consisted of chemical and biological testing of feed, feed ingredients and feed supplements, such as analysis of crude protein, fibre, moisture, mycotoxins and similar parameters. The service was found to be more appropriately classifiable under Heading 998346 as technical testing and analysis services, and not under Heading 9986 as animal husbandry support services. The scope of the exemption was held not to extend to such testing activity.

Conclusion: Testing of animal feed and related inputs is not covered by the exemption under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Ratio Decidendi: A testing service is not entitled to an exemption intended for specified agricultural operations or animal husbandry support services unless the service itself falls squarely within the exempted description.

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