Fact: Automobile Corporation of Goa Limited is receiving chassis of the bus from OEMs on FOC basis under the cover of delivery challan. They procure various inputs and services directly from OEMs which are used for carrying out the body building on the chassis received.
Issue Involved: Whether the activity of building and mounting of the body on the chassis by the Applicant will result in supply of goods under HSN 8707 or supply of services under HSN 9988.
Held: The Hon’ble AAR of Goa vide Advance Ruling No. GOA/GAAR/1 of 2017-18/2018-19/1929 dated August 21, 2018 stated that Chassis is semi-finished goods, so any treatment done by any other party on the chassis is the activity of the job work. As per section 2(68) of the CGST and SGST Act, the term job work means “any treatment or process undertaken by a person on goods belonging to another registered person and the expression ‘job worker’ shall be construed accordingly.” Hence, it should be classified as “supply of service” under HSN 9988 and taxable @ 18% GST.