Manpower services not exempt as 'Supply of Farm Labour' under SAC 99851. Recipient's engagement in agriculture not considered.

The Authority ruled that the exemption for "Supply of Farm Labour" services under specific notifications did not apply to the applicant's manpower services falling under SAC 99851. The questions concerning the recipient's engagement in agriculture and documentation requirements were deemed outside the Authority's purview for providing an advance ruling.

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Issues Involved:
1. Applicability of exemption for "Supply of Farm Labour" under specific notifications.
2. Requirement for the recipient of "Supply of Farm Labour" service to be fully engaged in agriculture.
3. Documentation and evidence needed for availing exemption under the relevant notifications.

Analysis:
1. The applicant, a sole proprietor of M/s. M.D. Enterprises, sought an advance ruling regarding the exemption of "Supply of Farm Labour" under specific notifications. The applicant supplied labour to a client for working in agriculture farms during the FY 2019-20. The recipient of the service owned agricultural land and immovable properties used for renting purposes. The applicant claimed exemption based on notifications exempting services related to cultivation and farm labour.

2. The Authority analyzed the classification of services and found that the applicant's services fell under SAC 99851 for manpower supply, not under Chapter heading 9986 for farm labour supply. The relevant notifications provided exemption specifically for services falling under Chapter heading 9986 related to farm labour supply, not under SAC 99851 for general manpower supply services.

3. The Authority concluded that the exemption for "Supply of Farm Labour" services under the notifications was not applicable to the applicant's manpower services falling under SAC 99851. Additionally, questions regarding the recipient's engagement in agriculture and documentation requirements were deemed beyond the Authority's scope for providing an advance ruling as per Section 97(2) of the GST Act, 2017.

In summary, the Authority ruled that the exemption for "Supply of Farm Labour" services under the mentioned notifications did not extend to the applicant's manpower services falling under SAC 99851. The questions related to the recipient's engagement in agriculture and documentation requirements were considered beyond the Authority's scope for providing an advance ruling.

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