Advance Ruling- Classification of Service- The Applicant has sought Advance Ruling on the following questions:-

1. Whether the applicant is eligible to avail the benefit of Notification No. 14/2018 - Central Tax dated 26.07.2018 as the non-profit association registered under any law engaged for the welfare of farmers vide serial No. 77A, Heading 9995?

2. Whether the doctrine of mutuality as laid down by the Supreme Court in various cases is applicable in our case?

3. It is clear that the Finance Act, 1994 (as amended from time to time) does not abrogate or do away with the doctrine of mutuality. The question that now need to be answered is whether the introduction of GST abrogates or does away with the doctrine of mutuality as laid down by the Supreme Court in various cases.

4. Is the applicant-association a person distinct from the member or a related person?

5. Is there a transaction between the applicant-association and its members which are covered under Section 7(1) (a), (c) or (d) of the Central Goods and Services Tax Act, 2017?

Authority for Advance Ruling, Tamil Nadu held that :-

1. The applicant is eligible to claim exemption vide serial number 77A of Notification No. 12/2017 Central Tax (Rate) as amended by Notification No. 14/2017 Central Tax (Rate) in respect of subscription received from natural persons who are farmers simpliciter and the annual aggregate subscription amount for all membership, under various nomenclature, up to Rs. 1000/-, as discussed in para 8.4.2 supra.

2. nterpretation of law is not mandated to Advance Ruling Authority under Section 97(2). Therefore, as discussed in para 6.1 supra, no ruling on the same.

3. Interpretation of law is not mandated to Advance Ruling Authority under Section 97(2). Therefore, as discussed in para 6.1 supra, no ruling on the same.

4. nterpretation of law is not mandated to Advance Ruling Authority under Section 97(2). Therefore, as discussed in para 6.1 supra, no ruling on the same.

5. Yes, there is transaction between the applicant-association and its members covered under Section 7(1)(a) and clarified by insertion of Section 7(1) (aa) and explanation with effect from 01st July, 2017 by Section 108 of the Finance Act, 2021 - brought into force on 01st January, 2022 vide Notification No. 39/2021-C.T dated 21st December, 2021.