Classification of service— In the instant case, the applicant is engaged in the business of body building of commercial vehicles used for carrying goods.

The applicant requested an advance ruling on the following:

1. Whether the activity of commercial vehicle's body building on job work basis, on the chassis supplied by the customer, is supply of goods or supply of services?

2. If it is a supply of goods, what is the applicable rate of GST?

3. If it is supply of services, what is the applicable rate of GST?

 The applicant is providing services of body building of commercial vehicles used for carrying goods on the chassis supplied by the customers. The body is built as per the requirement of the customers. The main issue to be determined is whether the activity constitutes supply of services or supply of goods.

Held that— The activity of tanker body building on the chassis supplied by the customer is a supply of service. 

The activity is liable to GST at the rate of [9% CGST + 9% SGST] as per entry at Sl No. 26 (iv) --- 9988 - "Manufacturing services on physical inputs (goods) owned by others - Manufacturing services on physical inputs (goods) owned by others, other than (i), (ia), (ib), (ic), (id), (ii), (iia) and (iii) above" of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017.