In re Jude Foods India Private Limited (GST AAR Tamilnadu)
Tamil Nadu Authority for Advance Ruling (AAR) in the case of In re Jude Foods India Private Limited examined the GST applicability on fish processing services. The applicant, Jude Foods India Pvt. Ltd., engaged in the direct sale of fish and the processing of raw fish supplied by customers, sought clarification on whether their services are classified under Heading 998812 as “Fish processing services” and taxed at 5% GST. Their process involves cleaning, cutting, freezing, and packaging fish or prawns, transforming them into frozen, ready-to-cook products with an extended shelf life.
The applicant contended that their services fall under the scope of “job work” as per Notification No. 11/2017-CT (Rate), which specifies a 5% GST rate for services involving the manufacturing of food products under job work. The activity was claimed to align with the definition of “job work,” involving treatment or processing of goods belonging to another registered person. The GST authorities confirmed no pending proceedings against the applicant regarding this issue, allowing the AAR to proceed with the application.
The AAR deliberated on several key issues, including the nature of the activity, its classification, and its compliance with GST provisions. The notification defines “job work” as a treatment or process performed on goods owned by another registered person. Jude Foods’ operations met these conditions, as the processing involves goods (fish and prawns) provided by registered principals. Consequently, the activity qualified as job work, allowing it to fall under the 5% tax bracket under Heading 998812 of the classification scheme.
