In re Jiva Sciences Private Limited (GST AAR Gujrat)
The present matter concerns an advance ruling sought by a GST-registered entity engaged in providing semen sorting services for bovine cattle. The applicant operates a specialized laboratory within the premises of Semen Stations where raw semen collected from bulls is processed using proprietary technology to separate X and Y chromosome-bearing sperm cells. After processing, the sorted semen is returned to the Semen Stations, which undertake further processing, packaging, and distribution of semen doses used for artificial insemination. The applicant sought clarity regarding the GST classification and taxability of semen sorting services, particularly whether such services qualify as exempt under GST and under which SAC code they should be classified.
The applicant argued that the services should fall under SAC 9986, which covers support services to agriculture and animal husbandry. According to the applicant, semen sorting is an intermediate step in the overall process of producing semen doses used for artificial insemination of bovine cattle. The applicant contended that the activity contributes to the rearing of animals, as the processed semen ultimately enables livestock breeding for milk production and other agricultural purposes. Since intermediate production processes carried out as job work in relation to rearing of animals fall within Heading 9986 and are eligible for exemption, the applicant maintained that semen sorting services should also qualify for exemption.
