TaxTMI 
TaxTMI 
2026 (9) TMI 1350
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.... 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 referred to as the Act) are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the Central Goods and Services Tax Act would also mean a reference to the same provisions under the Tamil Nadu Goods and Services Tax Act. M/s Jiva Sciences Private Limited, having place of business at Shop No. 8, Complex No. 73, Brindavanam Thirumana Mandapam, Mappedu, Tiruvallur-631402 (hereinafter called as the "Applicant") has registered with GSTIN 33AADCJ5419J1ZL under the Goods and Services Tax Act. They have filed this application for advance ruling under Section 97 of the CGST Act, 2017, and corresponding provisions under the Section 97 of TNGST Act, 2017. The Applicant has made a payment of application fees of Rs. 10,000/- under sub rule (1) of Rule 104 of CGST Rules, 2017 and TNGST Rules, 2017. 2. Statement of relevant facts h....
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.... b) The SAC code 998612, covers 'Animal Husbandry Services' and is taxable at GST rate of 18%. In light of the above, the Semen Sorting Services may get classified under this SAC code. 5. The applicant is under the administrative control of State. The concerned authorities of the Centre and State were addressed to report if there are any pending proceedings against the applicant on the issues raised by the applicant in the ARA application and for comments on the issues raised. As remarks have not been received from both the Centre and State authorities, it is assumed that there are no pending proceedings against the applicant on the issues raised by the applicant in the ARA application. 6. Personal Hearing The applicant was given an opportunity to be heard in person on 06.07.2026. Shri. Ankit Agarwal appeared for the personal hearing as the authorized representative (AR) of the applicant. The AR reiterated the submissions made in their application for advance ruling. The AR added that the Order in respect of the Advance ruling application on an identical issue relating to 'classification and taxation of the bovine semen sorting services' filed by the applicant before the ....
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....p 99861 Support services to agriculture, hunting, forestry and fishing 456 998611 Support services to crop production 457 998612 Animal husbandry services 458 998613 Support services to hunting 459 998614 Support services to forestry and logging 460 998615 Support services to fishing 461 998619 Other support services to agriculture, hunting, forestry and fishing 462 Group 99862 Support services to mining 463 998621 Support services to oil and gas extraction 464 998622 Support services to other mining nowhere else classified 465 Group 99863 Support services to electricity, gas and water distribution 466 998631 Support services to electricity transmission and distribution 467 998632 Support services to gas distribution 468 998633 Support services to water distribution 469 998634 Support services to distribution services of steam, hot water and air-conditioning supply 7.6. We note that as per Notification No....
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.... similar products or agricultural produce." 7.8. We now proceed to analyse if the 'semen sorting services' performed by the applicant fall within the definition of "Carrying out an intermediate production process as job work in relation to 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 or agricultural produce". 7.9. We note that the 'semen sorting services' involves: • receiving frozen or fresh semen from a semen station; • processing the semen using technology; • separating X-bearing and Y-bearing sperm; • returning the sorted semen for further processing and packing into semen straws 7.10. We note that the applicant is engaged in sorting semen, which is an independent, laboratory-based, technology-driven processing service performed on semen. The applicant delivers the sorted semen to the semen stations, which is one step before, and does not constitute or directly support, the process of the actual rearing, feeding, breeding management, or husbandry of livestock. It is, in substance, a value-addition/testing and....