माल और सेवा कर परिषद Goods & Se₹vices Tax Council

(1) Whether GST rate of @5% or 18%is applicable on the job work services of offset printing provided by the applicant on Kraft Paper and Duplex Paper supplied by the Corrugated box manufacturer/Packaging Industries w.e.f. 22.09.2025, in terms of Notification No.15/2025-Central Tax (Rate) dated 17.09.2025? 

(2) Whether paper cutting charges, paper sheet loading charges, bundle unloading charges and plate charges shown separately on Sale invoice, are ancillary to and form part of the principal supply of printing services, and whether the same GST rate applicable to printing service would apply to such charges?

Q1) Whether the royalty paid or payable by M/s Pink City Developers, as a Short-Term Permit holder in a mining area in Rajasthan, to the Government of Rajasthan is 'consideration for a service of granting the right to use minerals or mineral resources', taxable under SAC 997337, and liable to GST under the Reverse Charge Mechanism? 

Ans.- Yes, the royalty paid or payable by the applicant to the State Government of Rajasthan constitutes consideration for a 'service' by way of grant of right to use minerals or mineral resources, classifiable under SAC 997337, and is liable to Goods and Services Tax at 18% (9% CGST + 9% SGST) under the Reverse Charge Mechanism, to be discharged by the applicant as recipient. 

Q2) Whether the GST position applicable to a Quarry Lease or Mining Lease holder under the RMMCR, 2017 and the MMDR Act, 1957, in relation to payment of GST on royalty under RCM, also applies to M/s Pink City Developers as a Short-Term Permit holder? 

Ans.- Yes, the legal position applicable to a Quarry Lease/Mining Lease holder for discharge of GST on royalty under RCM is equally applicable to the applicant as a Short- Term Permit holder.

Q1) What is the applicable GST rate on Works Contract Services as on 01.06.2022? (HSN Code 9954: S. No. 3 / (iii) / (c) pipeline, conduit or plant for (i) water supply (ii) water treatment, or (iii) sewerage treatment or disposal.) Ans.- The applicable GST rate on Works Contract Services as on 01.06.2022 (HSN Code 9954: S.No. 3(iii) (c) pipeline, conduit or plant for (i) water supply (ii) water treatment, or (iii) sewerage treatment or disposal.) was 12% (6% CGST + 6% SGST).

1) Whether Papad Khar should be classified under HSN Code 2501 (Common Salts) @ 5% GST based on its alkaline salt composition and food application; OR 

2) Whether Papad Khar should be classified under HSN Code 2102 (Prepared Food Additives/Condiments) @ 5% GST based on its nature as a food processing ingredient: OR 

3) Whether Papad Khar qualifies for GST exemption under: Notification No. 2/2017-Central Tax (Rate), Entry 96 (Papad and related food items); OR Entry 23 (Unpacked food items and basic food ingredients); OR Any other applicable exemption notification;

 4) If the product is incorrectly classified under HSN 2836@ 18% GST, what is the correct classification and what relief/refund is available for past assessments?

(i) What is the correct classification and applicable GST rate on Washing/Laundry Soap (in BAR or CAKE form) used for washing clothes or toilet purposes as per Notification No.09/2025-Central Tax (Rate) dated 17.09.2025 effective from 22.09.2025? 

(ii) Whether such Washing/Laundry Soap for clothes and crockeries falls under the same GST rate and classification as Toilet Soap or under a separate tariff heading? 

(iii) What are the applicable 8 digit HSN codes and Rate of GST for Washing Soap, Laundry Soap, Crockeries Soaps and Toilet Soap under GST law?

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Q1) Whether Psyllium Seeds (Isabgol) 12119013 brought by cultivators/farmers to an Agricultural Produce Market Committee (APMC) and sold through the auction mechanism in their natural, raw and unprocessed form — without undergoing drying, dehydration, freezing, grading, polishing, crushing, milling, roasting, chemical treatment or any other processing activity — are classifiable under Tariff Item 12119013 and are accordingly exempt from levy of GST under Entry No. 87 of Notification No. 10/2025 -Central Tax (Rate) dated 17.09.2025, as amended from time to time? 

Ans.- Yes, the Psyllium Seeds (Isabgol) brought by cultivators/farmers to an Agricultural Produce Market Committee (APMC) and sold through the auction mechanism in their natural, raw and unprocessed form — without undergoing drying, dehydration, freezing, grading, polishing, crushing, milling, roasting, chemical treatment or any other processing activity — are classifiable under Tariff Item 12119013. However, the Psyllium Seeds (Isabgol) supplied by the applicant can not be said to qualify as "fresh" Isabgol seeds and are not exempted under Entry 87 (HSN 1211) of Notification No.10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or "chilled." The same are liable to tax @ 5% under Notification No. 09/2025-CT dt 17.09.2025. 

Q2) Whether threshing undertaken by cultivators for separating Psyllium Seeds (Isabgol) from the harvested crop constitutes merely a harvesting activity and not processing or manufacture for the purpose of classification and exemption under GST? 

Ans.- We do not find this question fit for pronouncement of ruling as it do not fall within the ambit of Section 97(2) of the GST Act.

Whether Notification 13/2020-CT (e-invoicing) applies where a registered parent/guardian/enterprise furnishes GSTIN and pays consideration; held applicable to genuine B2B supplies, but Authority declined to endorse the premise that every fee-paying registered person is automatically the "recipient" under Section 2(93)(a), since that determines place of supply (outside Section 97(2)); ITC eligibility in recipient's hands held independent of supplier's e-invoicing obligation.

GST rate on job work services for handicraft goods (5% concessional rate held applicable only while applicant is registered and goods are genuinely handmade); classification of resin statues (held under HSN 3926, not 9703 - not "original sculptures"); exemption for deities of marble (Ch. 68) and wood (Ch. 44) under Entry 124 of Notification 10/2025-CT(R).