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Issues: Whether the electroplating and related processing services carried out by the applicant on goods received from registered persons fall under entry 26(id) of Notification No. 11/2017-Central Tax (Rate) attracting GST at 12%, or under entry 26(iv) attracting GST at 18%.
Analysis: Entry 26(id) of Notification No. 11/2017-Central Tax (Rate), as amended, covers job work services within the meaning of section 2(68) of the Central Goods and Services Tax Act, 2017, namely treatment or processing undertaken on goods belonging to another registered person. Entry 26(iv) is a residual entry that specifically excludes services covered by entry 26(id) and applies only where the physical inputs are owned by persons other than those registered under the GST law. The applicant's services were performed on goods belonging to registered persons, and the circular issued by the tax administration clarified the same distinction between the two entries.
Conclusion: The applicant's services are covered by entry 26(id) and attract GST at 12%.
Ratio Decidendi: Where treatment or processing is undertaken on goods belonging to another registered person, the service is job work under section 2(68) and falls under the specific job work entry, not the residual manufacturing-services entry.