Sending Goods for Combi-Packing – Job Work or Supply?

In re Butterfly Gandhimathi Appliances Limited (GST AAR Tamil Nadu)

This article explores a case study regarding the interpretation of Goods and Services Tax (GST) in India, specifically concerning the activity of sending finished goods for combination packing (combi-packing) by another registered vendor. The case involves Butterfly Gandhimathi Appliances Limited (BGAL), a manufacturer of domestic appliances, seeking clarification on whether this activity constitutes a taxable supply or job work under GST.

Background:

BGAL manufactures various appliances like pressure cookers, mixers, and grinders. They plan to send finished goods they manufacture to a vendor who will pack them in combination with another GST-paid product procured by the vendor. This combi-pack will then be returned to BGAL for further taxable supply.

Applicant’s Interpretation:

BGAL argues that this activity doesn’t amount to a taxable supply for the following reasons:

• Job Work Definition: They cite Section 2(68) of the CGST Act, 2017, which defines “job work” as any treatment or process undertaken on goods belonging to another registered person. BGAL emphasizes that the section doesn’t differentiate between semi-finished and finished goods.
• GST Rules: They refer to Rule 45 of the CGST Rules, 2017, which allows sending inputs and capital goods for job work.
• No Tax Loss: BGAL asserts that since all goods are received back and taxed upon eventual sale, there’s no revenue loss to the government.

Central Authority’s Response:

The Central authority disagreed with BGAL’s interpretation, stating: