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2025 (7) TMI 383

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....olls. 3. The applicant has further stated as follows, viz * that their business involves job work of cutting metallic film rolls; * that the process involves receiving metallic film rolls from their clients, cutting them, returning the processed film rolls on bobbins; * that they cut metallic film rolls into specific dimensions, after which they are wound onto bobbins & returned to the clients; * that these rolls are used in the production of zari/metallic yarn, which is subsequently utilized in the making of sarees; * that their clients are registered with the department; * that their service is directly related to the textile industry. 4. The applicant has further stated that this application is on account of the ambiguity r....

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....f of the applicant and reiterated the facts as stated in the application. After the personal hearing, the applicant provided copies of invoices as requested during the course of personal hearing. 6.1 In pursuance to the transfer of Member (Centre), fresh personal hearing was held on 22.5.2025, wherein Shri Ashish Laheri, CA and Shri Kaushik Vaholiya, Partner, appeared on behalf of the applicant and reiterated their submission. Discussion and findings 7. At the outset, we would like to state that the provisions of both the CGST Act and the GGST Act are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same p....

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....of books (including Braille books), journals & periodicals; [(da) printing of all goods falling under chapter 48 or 49 which attract CGST @ 2.5% or Nil;] (e) and (ea) .... (f) all food & food products falling under chapters 1 to 22 in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975); (g) all products falling under chapter 23 in the first schedule to the Customs Tariff Act, 1975 (51 of 1975), except dog and cat food put up for retail sale falling under tariff item 23091000 of the said chapter; (h) ... (i) Manufacture of handicraft goods. Explanation.- The expression 'handicraft goods' shall have the same meaning as assigned to it in notification No. 32/2017-CT, dated 15.9.2017, published in the Gaze....

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....ailoring services. 2.5% -     (iv) Manufacturing services on physical inputs (goods) owned by others, other than (i), (ia), (ib), (ic). (ica), (id), (ii), (iia) & (iii) above 9% - 10. The applicant under the heading "Statement of the applicant's interpretation of the law", has stated the various rates that are applicable in respect of job work. These are already mentioned supra. 11. However, ongoing through the notification, ibid, we find that services by job work in relation to textile and textile products falling under chapters 50 to 63 in the first schedule to CTA '75 is leviable to GST @ 5% in terms of serial no. 26(i) while GST @ 12% is leviable in terms of serial No. 26(id) which is in respect of services b....

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....the applicable rates in respect of the job work done by the applicant would be either the GST rate mentioned at serial No. 26(i) or 26(id) of the notification, ibid. Let us first examine whether the job work done by the applicant i.e. cutting of metallic film rolls would fall under the ambit of serial No. 26(i)(b). Before moving on to the same, at the cost of repetition, we deem it appropriate to reproduce serial no. 26(i)(b), viz (i) Services by way of job work in relation to- (a) Printing of newspapers; (b) Textiles & textile products falling under chapters 50 to 63 in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975); The Hon'ble Supreme Court in the case of All India Federation of Tax Practitioners v/s UOI 2007 ....