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Goods and Services Tax

R&D for Government Bodies Taxable Under GST – No Exemption Allowed

Case Law Details

TaxGuru Citation
2025 taxguru.in 10155
Case Name
In re Laila Nutra Private Limited (GST AAR Andhra Pradesh)
Date of Judgement/Order
Only available for paid members
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In re Laila Nutra Private Limited (GST AAR Andhra Pradesh)

M/s Laila Nutra Private Limited (the applicant), a private limited company engaged in the business of extraction of concentrate from herbs and other products, filed an application before the Andhra Pradesh Authority for Advance Ruling (AAR) to determine the Goods and Services Tax (GST) implications of its Research and Development (R&D) activity. The applicant was selected to implement a project titled, “Development of Drug Master File (DMF) and Technical Dossier for Single Botanicals used in Ayurved” under the Ministry of AYUSH (MoA) through the Central Council for Research in Ayurvedic Sciences (CCRAS), the central nodal agency. The applicant was designated as a Sub-Nodal Agency under CCRAS.

The applicant was awarded two projects: Project 1, involving research, analysis, and manufacturing of 100 kg each of five different raw material extracts for further testing by other selected institutes, with a grant of approximately Rs. 10 Cr. Project 2 involves further testing, safety analysis, and reporting on one of the products from Project 1, also with a grant of approximately Rs. 10 Cr.

Deliverables and Funding Mechanism

The deliverables under Project 1 include 100 kg of each of five different raw material extracts (constituting less than 10% of the project cost) along with detailed research and analysis. The deliverable under Project 2 is a comprehensive Testing, Safety, and Analysis Report on one of the extracts. This report is intended to be placed in the public domain for reference.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,758

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