Classification and Tax Rate on Shot Blasting Services Provided
as Job Work
Summary of
Advance Ruling:
The applicant sought
classification and applicable GST rate for the shot blasting activity
performed on the castings of M/s. Ghatge Patil Industries Ltd. (GPI) at
GPI’s premises using the applicant’s own machine, steel shots, and labour.
The Authority ruled that
such services qualify as “job work” under SAC 9988 and are taxable at
12% GST (6% CGST + 6% SGST) under Sr. No. 26(id) of Notification
No. 11/2017-CT (Rate) as amended.
· Ruling
Number: GST-ARA-114/2019-20/B-27
· Date
of Ruling: 02 April 2025
·
Ruling Authority: Maharashtra
Authority for Advance Ruling (GST), Mumbai
·
Name of Applicant: M/s. Amruta
Fettlers (Sayaji Baburao Solase)
Questions
Raised:
1. Whether
shot blasting activity carried out at customer’s premises using own machinery,
materials, and labour qualifies as job work under SAC 9988?
2. Whether
the said activity is taxable at 12% GST under Sr. No. 26(id) of Notification
No. 11/2017-CT (Rate)?
Relevant
Sections / Notifications:
- Section 2(68)
of CGST Act – Definition of Job Work
- Section 2(72)
of CGST Act – Definition of Manufacture
- SAC 9988
– Manufacturing services on physical inputs (goods) owned by others
- Notification No. 11/2017-CT (Rate)
dated 28.06.2017
Amended via:
- Notification No. 1/2018-CT (Rate)
dated 25.01.2018
- Notification No. 20/2019-CT (Rate)
dated 30.09.2019 (effective 01.10.2019)
- CBIC Circular No. 126/45/2019-GST
dated 22.11.2019 – Clarification on Entry (id) and (iv)
Submission
by Applicant:
- Uses own machine, steel shots, and
manpower to perform shot blasting on GPI’s goods.
- Activity is performed within GPI
premises.
- Charges are based on per-piece.
- Believes it qualifies as job work
under Sec. 2(68).
- Cited precedents from Service Tax
era recognizing such activities as job work.
- Earlier charged 18% GST, but
after the insertion of entry (id), believes 12% GST is
applicable.
Submission
by Jurisdictional Officer:
- Agreed the activity qualifies as job
work under SAC 9988.
- Clarified it does not amount to
manufacture, but a process undertaken on goods of another
registered person.
- Applicable tax rate is 12% GST
as per Sr. No. 26(id) of Notification No. 11/2017-CT(R).
Discussion
and Findings:
- Shot blasting is a metal surface
treatment process using high-speed steel particles.
- Ownership
of goods remains with GPI, a registered person under GST.
- Meets definition of job work
under Sec. 2(68).
- Covered under Entry 26(id):
"Services by way of job work, other than specified items."
- CBIC Circular supports this
classification for services where goods belong to a registered person.
- SAC 998873
specifically includes metal treatment services like shot blasting.
Answers to
Questions:
1. Yes,
the activity qualifies as job work service under SAC 9988.
2. Yes,
the activity is taxable at 12% GST (6% CGST + 6% SGST) under Sr. No.
26(id) of Notification No. 11/2017-CT(R) as amended.
Conclusion:
The shot blasting
services provided by M/s. Amruta Fettlers to M/s. Ghatge Patil Industries
Ltd., using their own machinery and inputs on the goods owned by a
registered person, qualify as job work and are taxable at 12% GST
under SAC 9988, effective from 01.10.2019.
Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.
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