2018 (6) TMI 459

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....services or both, applicability of a notification issued under the provisions of the Act, Determination of the liability to pay tax on any goods or services or both under the Section 104 of CGST Act'2017 and Sec or. 104 of APGST Act'2017. The application was received by this authority on 1T January 2018, along with payment of Rs. 10000/- vide CPIN No: 18013700035704. The gist of questions on which advance ruling sought by the applicant is as follows: (a)   The applicant used to provide space to the farmers as well as traders far storage of agriculture produce such as Mirchi(Chillies), whole Pulses, Apples, Potato, Raw cashew nuts Oil seeds, maize ( Corn from maize ), Tamarind, Millets, Cattle feed etc., in his cold storage.....

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....c in nature. 3.   Further relied on circular 16/16/2017-GST, dated 15th November 2017, issued by TRU of Department of Revenue. 4.   For question No. 2(b), he submitted the entry doesn't have any specific reference to specific class of persons but to specific class of services, accordingly contended the benefit of the exemption should be extended for both to the farmers and to the traders. Further elaborated the services by traders are also as part of services for agriculture. 5.   For question No. c, he mentioned no specifications of maintaining of records in law. He requested to inform required documents to avail the exemption benefit. 4.1 We have gone through the application filed, the written and oral submiss....

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....als, except the rearing of horses, for food, fibre, fuel, raw material or other similar products or agricultural produce. Heading 9967 (Supporting services in transport) 4.2 On the perusal of above entries, we find that heading 9967 deals with support services in transportation. Whereas, heading 9986 deals with support services to agriculture, forestry, fishing, animal husbandry. Accordingly, we do not have any hesitation to rule out the heading 9967. As seen from the plain reading of the entry 54 and 55, it is evident that the services provided in activity of cultivation, from the initial stages up to the marketable stage, subject to conditions was 4nil rated. Among different support services for the cultivation or the agricultural oper....