Artificial Insemination of Livestock Exempt from GST: Gujarat AAR Defines 'Job Work' [Read Order]

The Gujarat Authority for Advance Ruling (AAR) defined ‘job work’ and reiterated that artificial insemination of livestock is exempt from Goods and Service Tax (GST).

The applicant, M/s Jiva Sciences Private Limited, collects raw semen by semen stations from the bulls. Operations within the semen sorting lab are managed by the applicant. The central issue in the present case is the qualification, classification and categorization of “Semen Sorting Services”.

The Departmental Representative argues that the services are classificable under - Other professional, technical and business services. The applicant is of the view that the activities undertaken by them would fall under either support services or as animal husbandry services.

The adjudicating authority observes that semen sorting may overcome surplus production of unwanted male calves which have low economic value. The authority also notes the definition of ‘job work’ as per Section 2(68) of the CGST Act, 2017:

‘Job work’ means any treatment or process undertaken by a person on goods belonging to another registered person and the expression ‘job worker’ shall be construed accordingly.

Since the services are provided to a registered entity, i.e., NDDB Dairy Services-Gujarat, it was observed that the services provided by the applicant would fall under the definition of ‘job work’. The bench added that the definition does not restrict the scope of work to purely labour-intensive tasks.

It held that the services of semen sorting are support services for animal husbandry and is an intermediate process in relation to rearing of animals.

The bench members Sushma Vora (SGST) and Vishal Malani (CGST) also noted that according to Entry No. 55A of Notification No.12/2017-CT(R) dated 28.06.2017 ‘services by way of artificial insemination of livestock (other than horses)’ are exempt from GST, and held accordingly. The same is backed by Entry No.24 which covers support services for agriculture, forestry, fishing, and animal husbandry.

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