Page 167 - GSTL_18th June 2020_Vol 37_Part 3

2020 ] IN RE : DOLPHIN DIE CAST (P) LTD. 381
referred to as “the applicant”) is private limited company registered with
GSTIN : 29AAACD5294L1Z6, filed an application for Advance Ruling under Sec-
tion 97 of the CGST Act, 2017 read with Rule 104 of the CGST Rules and Section
97 of the KGST Act, 2017 read with Rule 104 of KGST Rules, 2017, in FORM GST
ARA-01 and discharged the fee of Rs. 5,000/- each under the CGST Act and the
KGST Act.
2. The applicant is a manufacturer and exporter of Aluminium and
Zinc die Castings. The applicant first manufactures the Steel Die as per the re-
quirement and specifications given by the foreign customer. After seeking the
approval from the foreign customer, the applicant uses Steel Dies for making
Aluminium and Zinc Die Castings. These manufactured Aluminium and Zinc
Die Castings are exported to the overseas customer along with sub-assemblies
and other components against the order. However, the applicant retains the Steel
Die till the completion of the export order or completion of the life of the die.
3. The applicant has raised the tax invoice for the steel die in the name
of overseas customer in foreign currency for receipt of payment though the die
not physically exported to the foreign customer. However, after the completion
of the export order or completion of the life of the die, the applicant either export
the dies to the overseas customer or scrap the die at the applicant’s end as per the
instructions of the customer.
1 6. In view of the above, the applicant has sought an advance ruling in
respect of the following issues :
(a) Whether the applicant raise the tax invoice addressed to the foreign
buyer and delivery to applicant works by paying output GST and
claiming back by the applicant as input GST?
OR
(b) Whether applicant raise self-invoice by paying the output GST and
claiming back by the applicant as input GST?
OR
(c) Whether the applicant raise the tax invoice addressed to the foreign
buyer by paying the output GST under reverse charge mechanism?
OR
(d) Applicant seeks the procedure to be followed under GST Act for
discharging GST liability.
7. Further, the applicant submitted that the applicant places an order
for manufacture and supply of Aluminium casting and pressure die Casting
component of Aluminium to Thailand supplier (Foreign supplier). Thailand
supplier first manufactures the die as per the requirement and specification giv-
en by the applicant and after seeking the approval for dies, the Thailand supplier
manufactures and supplies the Aluminium casting and pressure die Casting
component of Aluminium to the applicant. However, the Thailand supplier re-
tains the steel die till the completion of the order or completion of the life of the
die.
8. Further, the applicant submitted that the Thailand supplier raised
the tax invoice for this die in the name of the applicant though the die not physi-
cally imported. However, after the completion of the order or completion of the
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1 Paragraph number as per official text.
GST LAW TIMES  18th June 2020  167