Classification of service— In the instant case, the applicant states that they are bidding for a tender called by Department of Horticulture which includes the supply of manpower for Bio-Centre, Department of Horticulture, Centre of Excellence for Floriculture, Tunga Horticulture Farm, Shivamogga, for maintenance of plants, tissue culture, production of mushroom and also for cleaning of offices.

The applicant has sought advance ruling in respect of the following questions:-

i. Whether works contract service provided to Bio Centers, Department of Horticulture and Center of excellence are exempted as per GST Exemptions?

ii. Whether other service like data entry operator, security, provided to Horticulture Department attracts GST?

iii. Whether material like fertilisers, soil, sand supplied for use of bio centers are exempted as per GST?

The applicant is providing manpower supply for tissue culture production and for handling the process of research on flowers, planting and growing for Horticulture department, Government of Karnataka. Now let us see whether tissue culture is covered under 1st entry of eleventh schedule which says 'Agriculture, including agricultural extension'.

Held that— 

i. Works contract service provided to Bio Centers, Department of Horticulture and Center of excellence are not exempted from GST.

ii. Providing Manpower service like data entry operator, security to Horticulture Department is exigible to GST at 18%( CGST @ 9% and KGST@9%).

iii. Materials like fertilisers, soil and sand supplied for use of bio centers are not exempted under GST.