The Uttar Pradesh Advance Ruling Agency (AAR) ruled that the bus body manufacturing activities are based on the main supply of goods and services.
Applicant, Adithya Automotive Applications Pvt. The company is engaged in body manufacturing and body installation on the chassis of different types of dump trucks, tankers, trucks and trailers. The applicant received the chassis of these items from TATA Motors and other customers based on the returnable challan. The applicant has described the manufacturing process as manufacturing steel plates, hollow steel pipes, round steel pipes, angle steels and steel channels according to required/required dimensions. With the help of welding electrodes (copper-plated wires), the above-mentioned steel parts are assembled/connected by welding to form the shape of the dump truck body. The assembly structure of the dump truck body is installed/fixed on the chassis by welding with the help of welding electrodes, and nuts and bolts are used in some places.
The applicant has sought an advance ruling on whether the bodybuilding activities on the chassis provided by the client is equivalent to a manufacturing service that attracts 18% consumption tax and whether to clarify the issue of CBIC. See paragraph 12.3 of Circular 52/26/2018-August 2018 The Goods and Services Tax on the 9th clarified that the 18% Goods and Services Tax rate also applies to applicants.
Coram of Vivek Arya and Abhishek Chauhan ruled that in the case of bus body manufacturing, there is a supply of goods and services. Therefore, the classification of this composite supply as a commodity or service will depend on which supply is the main supply, which can be determined based on the facts and circumstances of each case.
"We found that all the inputs needed to manufacture the body (dump truck, trailer, truck, tanker) on the chassis were purchased by the applicant, and the manufacturing body installed on the chassis was provided by the applicant. Therefore, in this case, It is the supply of the body, and the body assembly/installation activity on the chassis is a subsidiary activity of the main activity of the body supply. Therefore, according to the notice No. 34/8/2018-GST issued by CBEC on January 3, 2018 Clarified that the activity in question is compound supply, and the main supply is body supply,” the AAR ruled.
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