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168 GST LAW TIMES [ Vol. 39
28-7-2017 as amended further by Notification No. 32/2017-Central
Tax (Rate), dated 13-10-2017.
7. In view of the foregoing, we pass the following order.
RULING
Question : Whether the ‘Project Management Consultancy’ services
provided to Andhra Pradesh Panchayat Raj Engineering De-
partment for Andhra Pradesh Rural Road Project (APRRP)
for Road Construction can be termed as ‘Pure Services’ as
referred in Sl. No. 3 - (Chapter 99) of Table mentioned in No-
tification No. 12/2017-Central Tax (Rate), dated 28-6-2017
and accordingly eligible for exemption from Central Goods
and Services Tax and Sl. No. 3 - (Chapter 99) of Table men-
tioned in G.O. Ms. No. 588-(Andhra Pradesh) State Tax
(Rate), dated 12-12-2017 and accordingly eligible for exemp-
tion from Andhra Pradesh Goods and Services Tax.
Answer : Affirmative.
_______
2020 (39) G.S.T.L. 168 (A.A.R. - GST - A.P.)
BEFORE THE AUTHORITY FOR ADVANCE RULING UNDER GST,
ANDHRA PRADESH
S/Shri D. Ramesh, Member (State Tax) and M. Sreekanth,
Member (Central Tax)
IN RE : DECCAN TOBACCO COMPANY
AAR No. 36/AP/GST/2019, dated 24-10-2019
Tobacco leaves - Rate of GST - Procured at tobacco auction platforms
or directly from farmers - Cured and dried by farmers themselves - C.B.E. & C.
Instruction F. No. 332/2/2017-TRU, dated Dec., 2017 defining tobacco leaves,
classifiable under Heading 2401 of Customs Tariff Act, 1975, to mean as
“leaves of tobacco as such or broken tobacco/leaves or tobacco leaves stems” -
GST rate of 5% (CGST 2.5% + SGST 2.5%) applicable in terms of S. No. 109 of
Schedule 1 to Notification No. 1/2017-C.T. (Rate) - Procurement of said leaves
from other traders who have purchased same from farmers would also attract
same rate of GST under same heading - Further, processes like segregation or
redrying (without threshing) or butting, etc. do not alter basic character of to-
bacco leaves - Accordingly, even if these processes are carried out by applicant
on his own or on job work, before re-selling tobacco leaves to trad-
ers/manufacturers/ exporters, etc., GST rate would remain same, i.e., 5%
(CGST 2.5% + SGST 2.5%) under notification entry ibid. [para 7]
Tobacco leaves - Redrying with threshing - Unmanufactured tobacco -
Since redrying with threshing of cured tobacco leaves would convert product
into unmanufactured tobacco, same would go out of entry at S. No. 109 of
Schedule-1 to Notification No. 1/2017-C.T. (Rate) - Accordingly, said product
appropriately covered under entry at S. No. 13 of Schedule-IV to notification
GST LAW TIMES 13th August 2020 82

