Commission Agent Services for Chicks Not Exempt Under GST | AAR

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  • Last Updated on 10 July, 2025

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Case Details: Venkateshwara Hatcheries (P.) Ltd., In re - [2025] 175 taxmann.com 662 (AAR-MAHARASHTRA)

Judiciary and Counsel Details

  • D.P. Gojamgunde & Ms Priya Jadhav, Member

Facts of the Case

The applicant was engaged in promoting, marketing, and selling birds, specifically chicks, on behalf of its clients and functioned as a commission agent for such sales. The applicant submitted that the services rendered were in relation to the rearing of life forms of animals for agricultural purposes and therefore classifiable under Heading No. 9986. It was contended that such services qualified for exemption under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate), dated 28-06-2017. The core issue was whether the applicant’s services qualified as support services to agriculture including rearing of all life forms of animals or whether they constituted taxable intermediary services in general wholesale trade. The matter was accordingly placed before the Authority for Advance Ruling (AAR), Maharashtra.

AAR Held

The AAR Maharashtra held that the services provided by the applicant were not for the sale of any agricultural produce but were for the sale of livestock, specifically chicks, for the purpose of breeding. It was observed that such services did not amount to support services for any agricultural produce. The authority determined that the applicant’s services were classifiable under Heading No. 996111 and not under Heading No. 9986. Consequently, the exemption under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate), dated 28-06-2017 was held to be inapplicable.

List of Cases Referred to

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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