Classification of service— The applicant has sought advance ruling on the following;

Whether lease rent charged by the municipality for land i.e., water channel used for fish farming falls within the meaning of “services relating to rearing of all life forms of animals – by way of renting or leasing of vacant land” eligible for GST exemption as per Sl.No.54 of Notification No.12/2017-Central Tax (Rate) dated 28.06.2017 and corresponding notification under Kerala GST.

Held that— In the instant case, there is no doubt that the fish and crabs being reared by the applicant in the water channel taken on rent / lease are animals and the service of renting / leasing of the water channel has been availed by the applicant for the rearing of the animals. Therefore, the activity of renting 1leasing the water channel by the Grama Panchayat to the applicant for fish farming for a consideration determined through auction is squarely covered under the exemption entry at Sl No. 54 of Notification No. 12/2017 Central Tax (Rate) dated 28.06.2017 as services relating to rearing of all life forms of animals by way of renting or leasing of vacant land.—George Jacob, In Re… [2020] 24 TAXLOK.COM 076 (AAR-Kerala)