Classification of service— In the instant case, the applicant has sought Advance Ruling on the following questions:

1. Whether the activity of Bus Body Building on the chassis supplied by the customer on job work basis is a supply of service or supply of goods?

2. If it is supply of Service, what is the applicable rate of GST and its SAC code?

3. If it is supply of goods, what is the applicable rate of GST and its HSN?

In the instant case, it is observed that the bus body is fabricated and mounted by the Applicant on the chassis owned and supplied by the customer. After completing the work, it is delivered back to the customer, charging a lump sum amount as Job Work Charges. The ownership of the chassis remains with their customers and will not be transferred to the Applicant at any point of time. The consideration is received only towards fabrication services besides some materials involved in the course of fabrication.

Held that— The activity of bus body building undertaken on the chassis supplied by the customers to the Applicant amounts to supply of service as per Schedule II clause 3 of CGST Act 2017. The service rendered is classified under SAC 998881 and the applicable rate will be 18% (CGST @ 9 % and SGST @ 9 %).