Warehousing service in relation to storing bailed and pressed cotton is not exempt do not fall under Entry 24B Notification No. 21/2019 dated:30.09.2019 and hence are taxable at the rate of 18%.
Classification of service— In the instant case, applicant is Providing storage services to different customers and also to the Cotton Corporation of India which consists of storage of ‘Fully Pressed Cotton Bales’. They have submitted that Cotton Corporation of India is objecting to levy of GST on storage service by relying on Circular No.16/16/2017-GST issued by the Central Warehousing Corporation.
Question raised for advance ruling is as follows—
Whether the Godown Rent collected from the CCI is exempted as per the Notification 21/2019 – Central Tax (Rate) Dated 30.09.2019 based on the Circular No.16/16/2017-GST
The CCI has purchased raw cotton from farmers in the primary market and then processed it in ginning mills on job work basis. CCI has paid tax on ginning and pressing to the ginning mills as it cannot claim exemption under Entry 24 of the modified Notification No. 11/2017. This processing is not meant for primary market and hence it cannot be treated as raw cotton. Therefore it cannot be claimed that the cotton stored by CC! in the warehouses of the applicant fall under Entry 24B of Notification No. 21/2019 dated: 30.09.2019.
Held that— The warehousing services rendered by the applicant to CCI do not fall under Entry 24B Notification No. 21/2019 dated:30.09.2019 and hence are taxable at the rate of 9% under CGST and SGST each.
Warehousing service in relation to storing bailed and pressed cotton is not exempt do not fall under Entry 24B Notification No. 21/2019 dated:30.09.2019 and hence are taxable at the rate of 18%.
Classification of service— In the instant case, applicant is Providing storage services to different customers and also to the Cotton Corporation of India which consists of storage of ‘Fully Pressed Cotton Bales’. They have submitted that Cotton Corporation of India is objecting to levy of GST on storage service by relying on Circular No.16/16/2017-GST issued by the Central Warehousing Corporation.
Question raised for advance ruling is as follows—
Whether the Godown Rent collected from the CCI is exempted as per the Notification 21/2019 – Central Tax (Rate) Dated 30.09.2019 based on the Circular No.16/16/2017-GST
The CCI has purchased raw cotton from farmers in the primary market and then processed it in ginning mills on job work basis. CCI has paid tax on ginning and pressing to the ginning mills as it cannot claim exemption under Entry 24 of the modified Notification No. 11/2017. This processing is not meant for primary market and hence it cannot be treated as raw cotton. Therefore it cannot be claimed that the cotton stored by CC! in the warehouses of the applicant fall under Entry 24B of Notification No. 21/2019 dated: 30.09.2019.
Held that— The warehousing services rendered by the applicant to CCI do not fall under Entry 24B Notification No. 21/2019 dated:30.09.2019 and hence are taxable at the rate of 9% under CGST and SGST each.