The manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply.
Classification of service— In the instant case, the applicant is engaged in manufacturing of forgings, open and closed die forgings of carbon and alloy steel, micro alloy steel and stainless steel forgings.
The applicant sought Advance Ruling on the following question/issue.-
1. Whether the manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply or it may be said that manufacture of tooling kit is only incidental to the ultimate supply of forgings. Hence, the supply is only that of the forgings and not of the tooling kit?
2. Whether the amount recovered from Indian customers after the manufacture of tooling kit is excisable to CGST and SGST or IGST?
3. Whether the amount recovered from foreign customers after the manufacture of tooling kit can be treated as export and thus, zero rated?
In view of the above the issues before us to decide whether the manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply or it may be said that manufacture of tooling kit is only incidental to the ultimate supply of forgings, the amount recovered from Indian customers after the manufacture of tooling kit is excisable to CGST and SGST or IGST and the amount recovered from foreign customers after the manufacture of tooling kit can be treated as export and thus, zero rated.
Held that— The manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply.
The amount recovered from Indian customers after the manufacture of tooling kit is leviable to CGST and SGST or IGST.
The amount recovered from foreign customers after the manufacture of tooling kit cannot be treated as export.
The manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply.
Classification of service— In the instant case, the applicant is engaged in manufacturing of forgings, open and closed die forgings of carbon and alloy steel, micro alloy steel and stainless steel forgings.
The applicant sought Advance Ruling on the following question/issue.-
1. Whether the manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply or it may be said that manufacture of tooling kit is only incidental to the ultimate supply of forgings. Hence, the supply is only that of the forgings and not of the tooling kit?
2. Whether the amount recovered from Indian customers after the manufacture of tooling kit is excisable to CGST and SGST or IGST?
3. Whether the amount recovered from foreign customers after the manufacture of tooling kit can be treated as export and thus, zero rated?
In view of the above the issues before us to decide whether the manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply or it may be said that manufacture of tooling kit is only incidental to the ultimate supply of forgings, the amount recovered from Indian customers after the manufacture of tooling kit is excisable to CGST and SGST or IGST and the amount recovered from foreign customers after the manufacture of tooling kit can be treated as export and thus, zero rated.
Held that— The manufacture of tooling kit for further manufacture of forgings is to be treated as a separate supply.
The amount recovered from Indian customers after the manufacture of tooling kit is leviable to CGST and SGST or IGST.
The amount recovered from foreign customers after the manufacture of tooling kit cannot be treated as export.