2026 (3) TMI 1294

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.... only- (a) on the applicant who had sought it in respect of any matter referred to in sub-section (2) of Section 97 for advance ruling. (b) on the concerned officer or the jurisdictional officer in respect of the applicant. 3. In terms of Section 103(2) of the Act, this advance ruling shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed. 4. Advance Ruling obtained by the applicant by fraud or suppression of material facts or misrepresentation of facts, shall render such ruling to be void ab initio in accordance with Section 104 of the Act. 5. The provisions of both the Central Goods and Services Tax Act and the Tamil Nadu Goods and Services Tax Act (herein ref....

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....atement of relevant facts: 3.1 The applicant operates a poultry farming business focused on egg production. The eggs are packed into boxes and sold without any processing. The packaging is made to meet customer requirements and quality standards. The poultry farming activities are conducted on a mix of owned and leased farms. 4. Interpretation of Law by the Applicant based on the statement of facts: 4.1 The applicant submits relevant extract of exemption Notification No. 12/2017-CT(R) of CGST Act, 2017, as follows: "agricultural produce" means any produce out of cultivation of plants and rearing of all life forms of animals, except the rearing of horses, for food, fibre, fuel, raw material or other similar products, on whi....

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..... Mr. R. Jothilingam, Accounts Manager of M/s. Umapathy Poultry Farms, Mr. S. Harishankar, Chartered Accountant and Mr. S. Pradeep, Chartered Accountant appeared as Authorized Representatives of the applicant. The AR reiterated the submissions made in their application for advance ruling. 6.3 The AR informed that they are cleaning and packing the eggs and transporting them to dealers situated all over India. They informed that they use cardboard packing box for packing the eggs; that they use various packages having labelling and branding of the customers for packing the eggs as per the requirements of their customers. The AR also informed to the Members that the Goods Transporters and the Railway authorities had told them that they need....

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....icant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of Section 100 or of section 101C, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant; 7.3 From the applicant's submission, it is understood that the applicant is recipient of the services namely transportation of goods by Road, transportation of goods by Rail, leasing of agricultural land with or without shed or for grazing and sheltering hens. As per Section 95 (a) of the CGST Act, 2017, decision can be provided by the Authority on questions relating to the services being undertaken or proposed to be undertaken by the applicant. In the instant case, the applicant is a recipien....