Testing services for animal feed not exempt under tax notification

The Authority determined that the services provided by the Applicant, involving testing of animal feed, did not qualify for exemption under Notification No. 12/2017-Central Tax (Rate) for both CGST and SGST Acts. The ruling clarified that the Applicant's services related to testing animal feed and feed ingredients were not covered under the mentioned notification.

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Issues:
- Applicability of Notification No. 12/2017-Central Tax (Rate) to services related to rearing of animals by way of testing
- Classification of services provided by the Applicant under the GST regime

Analysis:

Issue 1: Applicability of Notification No. 12/2017-Central Tax (Rate) to services related to rearing of animals by way of testing

The Applicant sought an Advance Ruling to clarify if their services related to rearing animals through testing of animal feeds, feed ingredients, and supplements fall under the exemption provided by Sl.No. 54 of Notification 12/2017-Central Tax (Rate). The Applicant highlighted that testing of feeds is crucial for proper rearing of animals to ensure nutritional value, detect contaminants, adulterants, mycotoxins, and overall quality. They argued that their services were exempted under the pre-GST regime and should continue to be exempt under GST.

The Authority examined the nature of services provided by the Applicant, which involved testing various parameters of animal feed samples. The Applicant charged for tests such as Crude Protein, Crude Fibre, Moisture, Multi Mycotoxins, among others. The Authority noted that the Applicant's activities primarily focused on testing the chemical and physiological composition of animal feed samples. The Applicant's services were found to be more aligned with technical testing and analysis services (SAC 998346) rather than support services to animal husbandry (SAC 998612) as per the classification under GST.

Issue 2: Classification of services provided by the Applicant under the GST regime

The Authority determined that the services of the Applicant, involving testing of animal feed, did not fall under the purview of the exemption provided by Notification 12/2017-Central Tax (Rate) dated 28/06/2017. The services were deemed ineligible for exemption under both CGST and SGST Acts. The ruling clarified that the Applicant's services related to testing of animal feed and feed ingredients were not covered under the mentioned notification.

In conclusion, the Authority ruled that the services provided by the Applicant concerning the testing of Animal Feed and Feed ingredients were not eligible for exemption under Notification 12/2017-Central Tax (Rate) dated 28/06/2017 for both CGST and SGST Acts.

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