18% GST leviable on plantation of mangrove seeds & seedlings in coastal areas: AAAR

  • Blog|News|GST & Customs|
  • 2 Min Read
  • By Taxmann
  • |
  • Last Updated on 12 January, 2023

GST Rates

Case Details: Appellate Authority for Advance Ruling, West Bengal Raj Mohan Seshamani, In re - [2023] 146 taxmann.com 155 (AAAR-KOLKATA)

Judiciary and Counsel Details

    • Ashutosh Awasthi & Khalid Aizaz Anwar, Member
    • Rip Das for the Appellant.
    • Biswanath Purkait for the Respondent.

Facts of the Case

The appellant was engaged in business of cultivation, planting and nurturing of mangrove seeds and seedlings in coastal areas for environmental organizations with objective of environmental protection against cyclones and tidal waves in order to create sustainable development and livelihood for people. It filed an application for advance ruling to determine taxability of plantation of mangrove seeds and seedlings in coastal areas.


The Authority for Advance Ruling (AAR) ruled that sole object of services would be to enhance biodiversity and re-establish ecosystem function to protect islands. Hence, this activity would be categorized under “environmental protection services” with Heading No.9994 and tax shall be levied at 18%. It filed appeal against the order of AAR and submitted that this activity should be covered under Serial No. 24 of Notification No. 11/2017- Central Tax (Rate) dated 28/06/2017 having SAC 9986 and therefore it shall attract Nil rate of tax.

The Appellate Authority for Advance Ruling observed that the aforesaid services provided by appellant would primarily be used for purpose of environmental protection and would not be related to cultivation of plants for food, fibre, fuel, raw material or other similar products. Therefore, there would be no infirmity in ruling pronounced by AAR that supply of services for plantation of mangrove seeds and seedlings in coastal areas would be covered under Serial Number 32 of Notification No. 11/2017-Central Tax (Rate) dated 28-6-2017 having SAC 9994 and shall attract 18% GST.

Disclaimer: The content/information published on the website is only for general information of the user and shall not be construed as legal advice. While the Taxmann has exercised reasonable efforts to ensure the veracity of information/content published, Taxmann shall be under no liability in any manner whatsoever for incorrect information, if any.

Leave a Reply

Your email address will not be published. Required fields are marked *

Everything on Tax and Corporate Laws of India

To subscribe to our weekly newsletter please log in/register on Taxmann.com

Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied