Building and mounting body on customer chassis is job work and taxable as service under Schedule II(3) of CGST Act

AAR held that the activity of building and mounting a body on a customer-supplied chassis is job work and constitutes a supply of services under Schedule II(3) of the CGST Act. The applicant uses its own materials and invoices separately for body-building charges while ownership of the chassis remains with the customer; consideration received is for manufacturing the body. Accordingly, the transaction is taxable as supply of services under CGST/TNGST.

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Issues: Whether the activity of building and mounting the body on a chassis made available by the customer amounts to a supply of goods or a supply of services under the CGST/TNGST Act, 2017.

Analysis: The ruling applies the statutory definitions and provisions relevant to job work and classification of supply: Section 2(68) (definition of job work), Section 2(52) (definition of goods), Section 143 (treatment of inputs for job work), and Para 3 of Schedule II (treatment or process applied to another person's goods is a supply of services). Relevant administrative guidance in Circular No.52/26/2018-GST distinguishing (a) supply of a built vehicle by a body builder (taxed as goods) and (b) fabrication on chassis provided by the principal (treated as service) is applied. Factual findings relied on are that the chassis remained owned by the customer throughout, the applicant subcontracted fabrication to vendors who used their own materials to perform erection/fabrication work on customer-owned chassis, and the applicant raised invoices charging fabrication/body-building charges separately.

Conclusion: The activity of building the body on a truck/chassis made available by the customer qualifies as job work/treatment or process on another person's goods and therefore constitutes a supply of services under Schedule II clause 3 of the CGST Act, 2017; the body-building activity is to be treated as a service (SAC 998881) attracting GST as per the applicable classification.

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