Case Details: In re: Jiva Sciences Pvt. Ltd. (2026) 41 Centax 389 (A.A.R.-GST-Guj.)
Judiciary and Counsel Details
- Ms Sushma Vora & Shri Vishal Malani, Members
- S/Shri Naveen Kumar & Mukul Jain, Authorised Representatives, for the Applicant.
- Shri N.G. Patel, for the Respondent.
Facts of the Case
The applicant, engaged in separating X and Y chromosome-bearing sperm cells from bovine semen through technology intervention, operated a semen sorting laboratory within the premises of semen stations for the production of sorted semen. It was submitted that raw semen was collected by semen stations from bulls and processed by the applicant using proprietary technology, while all personnel working in the sorting laboratory were employees of the applicant. The applicant sought an advance ruling on the appropriate classification of semen sorting services and whether such services qualified as exempt services under GST, similar to the exemption granted to semen doses. The matter was accordingly placed before the Authority for Advance Ruling (AAR).
AAR Held
The AAR held that the services of semen sorting provided by the applicant constituted support services for animal husbandry and were an intermediate process in relation to rearing of animals. It held that the services were covered under sub-item (iii) of Sl. No. (i) of Entry No. 24 of Notification No. 11/2017-Central Tax (Rate), dated 28-06-2017. The AAR therefore held that the services would fall under Heading 9986 and would be exempt from payment of GST.
List of Notifications Cited
- Notification No. 11/2017-Central Tax (Rate), dated June 28, 2017
