As per the Notification 12/2017 CT (R), S.no. 21(a) Services provided by GTA by way of transport in goods carriage of :- Agricultural Produce is Exempt.
and if read the definition of agriculture produces in the said notification , The product on which no processing is done or such processing is done as is usually done by a cultivator which does not alter its essential characteristics but make it marketable for primary market would fall within the definition of agriculture produce.
In my view cashew nut are being process by processor before marketable so does not fall under agriculture products.
Hence Recepient is required to do RCM & it's not Exempted.
Yes it's exempted only if it is provided to Govt, which has taken registration in GST only for the purpose of deducting under section 51 & not for making a taxable supply of Goods or Services.
(Ref : Notification 12/17 CT rate , s.no. 21B)
More clarification anshuman you can call me.
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