In Re: M/s. Monrovia Leasing and Finance Pvt. Ltd.
GST
2018 (10) TMI 1244 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – 2018 (18) G. S. T. L. 489 (A. A. R. – GST)
AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – AAR
Dated:- 4-8-2018
GST-ARA-20/2017-18/B-83
GST
SHRI B.V. BORHADE, AND SHRI PANKAJ KUMAR, MEMBER
PROCEEDINGS
Under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017)
The present application has been filed under section 97 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017 [hereinafter referred to as “the CGST Act and MGST Act”] by M/S Monrovia Leasing and Finance Pvt. Ltd., the applicant, seeking an advance ruling in respect of the following questions.
1. Whether the whole (Sheep/Goat) animal carcass in its natural shape in frozen state in different weight and size packed in LDPE bags without mentioning the weight and one or two such LDPE bags fu
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mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST Act / MGST Act would be mentioned as being under the “GST Act”.
02. FACTS AND CONTENTION – AS PER THE APPLICANT-
1) M/S Monrovia Agro Foods is engaged in slaughtering & processing of Sheep / Goat meat and supplies these products to Army against tender.
2) Monrovia Agro Foods Supplies to Army Sheep / Goat meat in carcass form i.e. the whole animal carcass in its natural shape in frozen state. Naturally, the carcass would be in different weight & sizes. Further, there is no fixed quantity & size in which these carcasses are dispatched to Army. The said dispatches are made on the basis of the weight of the frozen carcass. Furthermore, the consideration is charged on the basis of weight. The packing and dispatch pattern is given below:-
Each frozen carcass is put in LDPE Bag (Primary Packing) whic
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meat respectively are provided below:
Schedule II
S.No.
Chapter/ Heading/ Sub-heading/ Tariff item
Description of Goods
4.
0204
Meat of sheep or goats, frozen and put up in unit containers
b. A reading of the above-mentioned entries in the above reproduced notification would reveal that if the items mentioned in Tariff Heading 0204 are put up in a 'unit container', it would be eligible to tax @ 12%.
c. Correspondingly, in exercise of the powers conferred by sub-section (1) of section 6 of the Integrated Goods and Service Tax Act, 2017, the Central Government via Notification No.2/2017-Integrated Tax (Rate) New Delhi dated 28.06.2017 has exempted inter-State supplies of goods from the whole of the integrated tax leviable thereon as under. Relevant extract is reproduced below;
Schedule
S.No.
Chapter/Heading/Sub-heading/Tariff item
Description of Goods
10.
0204
Meat of sheep or goats, [other than frozen and put up in unit containers]
A conjoint reading of the extracts o
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e any actionable claim or enforceable right in respect of such brand name has been foregone voluntarily], subject to conditions as in the ANNEXURE I]”;
b. Hence, net impact of the above amendment is as follows:-
i. Reduction in rate from 12% to 5% on the subject products.
ii. One additional condition for taxability is imposed i.e. product must be branded.
c. Correspondingly, in exercise of the powers conferred by sub-section (1) of section 6 of the Integrated Goods and Service Tax Act, 2017, the Central Government via Notification No.44/2017-Integrated Tax (Rate) New Delhi dated 14.11.2017 has exempted inter-State supplies of goods from the whole of the integrated tax leviable thereon as under. Relevant extract is reproduced below:
Schedule
S.No.
Chapter/Heading/Sub-heading / Tariff item Heading
Description of Goods
8.
0204
All goods, fresh or chilled
9.
0204
All goods (other than fresh or chilled) other than those put up in unit container and,-
(a) bearing a register
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half-carcasses of lamb, fresh or chilled
Nil
0204 22 00
– Other cuts with bone in
Nil
0204 23 00
– Boneless
Nil
0204 30 00
– Carcasses and half-carcasses of lamb, frozen – Other meat of sheep, frozen:
Nil
0204 41 00
– Carcasses and half-carcasses
Nil
0204 42 00
– Other cuts with bone in
Nil
0204 43 00
– Boneless
Nil
0204 50 00
– Meat of goats
Nil
1601 00 00
SAUSAGES AND SIMILAR PRODUCTS, OF MEAT, MEAT OFFAL OR BLOOD; FOOD PREPARATIONS BASED ON THESE PRODUCTS
6%
0104
LIVE SHEEP AND GOATS
0104 10
– Sheep:
0104 10 10
– Sheep including lamb for breeding purpose
0104 10 90
– 0104 10 90
0104 20 00
– Goats
(c) Details of benefit of notification of Central Excise if any availed – NA.
(6) (a) Classification of Service / Services as applicable
(b) Rate / Rates of Service Tax as applicable to services provided
Sr. No.
Classification of Services
Accounting Code
Rate of Tax
1.
Manpower Recruitment/ Suppl
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017 till 14th November, 2017
Schedule II of the Notification No 1/2017-lntegrated Tax (Rate) dated 28th June 2017 deals with the products which are subject to 12 % GST and entry No 4 which pertain to sheep/Goat meat respectively are provided below:
Schedule II
S.No.
Chapter/Heading/Sub-heading/ Tariff item
Description of Goods
4.
0204
Meat of sheep or goats, frozen and put up in unit containers
3. A reading of the above-mentioned entry in the above reproduced notification would reveal that if the items mentioned in Tariff Heading 0204 are put up in a 'unit container', it would be eligible to tax @12%.
4. Correspondingly, in exercise of the powers conferred by sub-section (1) of section 6 of the Integrated Goods and Service Tax Act, 2017, the Central Government via (b) Notification No.2/2017-lntegrated Tax (Rate) New Delhi dated 28.06.2017 has exempted, inter-State supplies of goods, from the whole of the integrated tax leviable thereon. Relevant extract is reproduc
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Tariff Heading 0204 would be eligible to tax @ 5% if are put up in a 'unit container' and bear a brand name.
7. Correspondingly, in exercise of the powers conferred by sub-section (1) of section 6 of the Integrated Goods and Service Tax Act, 2017, the Central Government via Notification No.44/2017-Integrated Tax (Rate) New Delhi dated 14.11.2017 has exempted, inter-State supplies of goods, from the whole of the integrated tax leviable thereon. Relevant extract is reproduced below:
Schedule
S.No.
Chapter/Heading/Sub-heading/Tariff item
Description of Goods
8.
0204
All goods, fresh or chilled
9.
0204
All goods (other than fresh or chilled) other than those put up in unit container and,-
(a) bearing a registered brand name; or
(b) bearing a brand name on which actionable claim or enforceable right in court of law is available [other than those where any actionable Claim or enforceable right in respect of such brand name has been foregone voluntarily], subject to conditions
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Sheep/ Goat meat to Army against tender does not qualify to be as unit container.
In support of above point of view, following submissions are being made for the kind consideration of the Honorable Advance Ruling Authority.
11. Unit Container, meaning-
11.1 Before adverting to the decided case laws and analysis of the term 'unit container', it is important to advert to the meaning of the term 'unit'. Merriam Webster Dictionary defines 'unit' as 'a determinate quantity (as of length, time, heat, or value) adopted as a standard of measurement such as an amount of work used in education in calculating student credits or an amount of a biologically active agent (such as a drug or antigen) required to produce a specific result. The Business Dictionary defines the term to mean a definitive or determinate quantity adopted as a standard of measurement and exchange. Therefore, where the term 'unit' is affixed to a container, it would mean a container containing a 'unit' of a particular com
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nder the old Central Excise Tariff, prepared/ preserved food put up in 'unit container' and ordinarily intended for sale were eligible for excise duty. Thus, there was a twin requirement viz. goods being put up in 'unit container' and secondly, they should have ordinarily been intended for sale.
11.6 The expression 'unit container' was not defined in the old Central Excise Tariff but instructions in this regard were issued by Central Excise Board's letter M.F (D.R.I.) No. B/ 5/1/69-CX-I, dated 3-4-1969, clarifying the meaning of the term 'unit container' as under:
“Meaning of unit Containers. The expression 'unit container' used in Tariff Item 1B means a container in which prepared or preserved food is intended to be sold by the manufacturer. It may be a small container like tin, can, box, jar, bottle or bag in which the product is sold by retail, or it may be a large container like drum, barrel or canister in which the product is packed for sale to other manufacturers or dealers. In
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ned quantity of the contents. To pack half a litre of fruit syrup in a bottle which can hold one litre would not only be wasteful but would also subject the contents unnecessary movement, perhaps with a loss of quality. Further, it would arouse doubts in the customer that he is being cheated. It can therefore be very well understood that no intelligent manufacturer would pack prepared or preserved foods (or indeed any similar product of common consumer use) in a container which is not full or practically so. Nor would a prudent customer readily buy a product in a container which does not appear to be full.
46. The above observations on the methods of marketing of common consumer products, do not require any special knowledge because they are a matter of common experience. The tariff item and the Finance Ministry's instructions are consistent with the general experience and practice as mentioned above. General experience would certainly show that prepared and preserved foods and the li
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the term 'unit'.
11.9 Under the new Central Excise Tariff Act, 1985 (which replaces the old Tariff) also, certain products cleared and manufactured and put up in a 'unit container' were eligible to excise duty. The term 'unit container' under the New Central Excise Tariff Act, 1985 was defined to mean as under:
“Container whether large or small (for examples, tin, can, box, jar, bottle, bag or carton, drum, barrel, or canister) designed to hold a pre-determined quantity or number.”
11.10 In the context of new Central Excise Tariff Act, 1985, in the case of Agro Foods Punjab Ltd. v. Collector of Central Excise, 1990 (49) E.LT. 404 = 1990 (3) TMI 194 – CEGAT, NEW DELHI, the tribunal observed as below:
“We hold that there is no difference either in the entry in between 1B of the old Tariff and new tariff 2001.10 or in the issue involved in both the cases. Following the ratio of the decision in the case of M/s. HPMC we hold that clearance in barrels does not amount to sale of the con
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nit container' or not so long as the said container contained a predetermined quantity.
11.14 In the context of HDPE and LDPE Bags, in the case of Surya Agro Oils Ltd. v. Commissioner of Central Excise, Indore, 2000 (116) E.L.T. 514 = 1999 (11) TMI 264 – CEGAT, NEW DELHI, the question arose whether an HDPE sack weighing 20 kg each of Pasta was a 'unit container' or not. It is pertinent to note that the HDPE sack weighing 20kgs comprised of 2 LDPE bags weighing each and after putting the said LDPE bags in the HDPE sack, the HDPE sack was stitched and subsequently it was cleared as an HDPE. The tribunal opined as under.
* There exists no logic to restrict the scope of the words 'unit container' only to small containers which must have predetermined capacity of 1/2/3/4/ kg., and carry full particulars of the product i.e., date of the manufacture, name of the manufacturer, trademark price, etc. If the intention of the legislature was to refer only to the small containers having predeter
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xample, tin, Can, box, jar, bottle, bag, or carton, drum, barrel, or canister) designed to hold a Predetermined quantity or number, which is indicated on such package.”
12. In view whereof the judicial principles evolved for determination of 'unit container' would hold good in the context of GST law as well. We are therefore summarizing the said principles as under: In order for a container to be categorized as a 'unit container' , the said container should be designed to hold a predetermined quantity and should be standardized i.e. it is standardized for a particular commodity like packages of 1kg, 100 ml, 200ml, etc.
(i) The words 'unit container' does not mean only small containers which must have predetermined capacity of 1/2/3/4/ kg., and carry full particulars of the product i.e., date of the manufacture, name of the manufacturer, trademark, price, etc. A big container designed to hold a pre-determined quantity of goods in bulk will also qualify as 'unit contained.
(ii) That
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her a container is a 'unit container' or not, we are of the view that the fact that the LDPE bags are not sealed would militate against any contention raised by the department that the said container are designed to hold a pre-determined quantity.
(ii) That in Surya Agro Oils Ltd. v. Commissioner of Central Excise, Indore, 2000 (116) E.LT. 514 = 1999 (11) TMI 264 – CEGAT, NEW DELHI, case wherein HDPE sack weighing 20 kg each of Pasta comprising of 2 LDPE bags weighing 10 kgs each was held to be a unit container will not be applicable to the present case in as much as in the said case the HDPE bag contained LDPE bags of 10Kgs each, which were standardized whereas in the present case there is no fixed quantity of mutton in the LDPE bags, it can weigh 7 kg or 6.5kg i.e. the said HDPE bags cannot be said to be holding a predetermined uniform quantity. In a nutshell, the bags in the present case do not hold a pre-determined quantity of meat. It is clear from the above factual matrix that
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view that the product supplied by Monrovia Agro Foods shall not qualify as unit container.
15. Applicant submitting the two advance ruling by Hon. ARA Of Haryana State which is in support of our stand and interpretation that the product We are supplying should not qualify as packed in unit container, should not be subject to tax.
15. Applicant's point of view on specific queries raised for Advance Ruling:-
i. Whether the packaging being used for despatch to Army shall qualify as “Unit Container” under the GST law?
Point of view:-ln light of the discussion contained in Para 11.1 to Para 11.12, we are of the view that despatches made by the supplier in LDPE/ H DPE bags i.e. both primary as well as secondary packing do not qualify as product packed in unit container.
ii. Whether the product, i.e. sheep/Goat meat in frozen State and packed as mentioned in the facts stated above sheet shall be liable to be taxed under GST or would it be treated as exempted?
Point of view: -In lig
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xample, tin, can, box, jar, bottle, bag, or carton, drum, barrel, or canister) designed to hold a predetermined quantity or number, which is indicated on such package.
Thus it can be seen that the above referred Notifications has clearly brought out what a “unit container” means. If the submission made by the tax payer is taken on face value that they are engaged in supply of whole (Sheep/Goat) animal carcass in its natural shape in frozen state in different weight and size packed in LDPE bags without mentioning the weight and one or two such LDPE bags further packed in HDPE bags without mentioning the weight, the goods supplied by the tax payer cannot be construed as a product put up in “unit container” as the package i.e. LOPE bags and HDPE bags even though be designed to hold a pre-determined quantity/weight, the same is not indicated on such packages nor the same are numbered. Further on being asked to clarify the weighment procedure adopted by the taxpayer, the taxpayer has subm
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28th June 2017 up to 14th November 2017 and thereafter as per entry no. 1 of schedule I of the Notification No. 43/2017-lntegrated Tax (Rate) dated 14th November 2017 or fall under exemption list as per entry no 10 of Notification No. 2/2017-lntegrated Tax (Rate) New Delhi dated 28th June 2017 up to 14th November 2017 and thereafter as per entry no. 9 of the Notification No. 44/ 2017-lntegrated Tax (Rate) dated 14th November 2017.
Comments: As per the submissions made by the tax payer it appears that they are supplying Sheep, Goat Meat in carcass form i.e. the whole animal in its natural shape in frozen state of different weights. The said products are packed in LDPE bags and then one or two LDPE bags are packed in one HDPE bag. As the packages differ in weight and quantity, no weight is mentioned on the LDPE or HDPE bags and invoicing is done on the entire weight of the lot. It appears that the product involved i.e. Frozen Sheep/Goat Meat is duly covered under HS Code 02043000 and Ch
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pter/Heading/Sub-heading/Tariff item
Description of Goods
10
0204
Meat of sheep or goats, fresh, chilled or frozen [other than frozen and put up in unit container]
Similarly from 15.11.2017 the said product appears to fall under Entry No: 9 of Notification No: 44/2017-Integrated Tax (Rate) dated 14.11.2017 as the product is not put in unit containers and not bears a registered brand name.
As per the Oral directions issued by the Hon'ble Advance Ruling Authority during the course of hearing held on to verify and report whether the applicant M/S Monrovia Leasing Finance Pvt. Ltd was using any brand name on the goods on which the Advance Ruling is sought for, this office had deputed the Jurisdictional Range Superintendent Shri Rajesh Surendran, to physically verify the goods and report. Based on the verification report of the deputed officer, the following submission is placed before the Hon'ble Authority for the perusal.
a) The whole (Sheep/Goat) animal carcass in its natural sha
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was also noticed that the Tax payer is also involved in the manufacture of Ready to cook Chicken products, Tray Pack Frozen Pre Cut Chicken Products and Ready to eat Canned Meat Products. The said goods are marketed and sold under a Brand “Punjab Maratha” in retail packs on which the tax payer is paying appropriate GST. The brochure, the packing and the stickers used for the packing are enclosed for ready reference.
04. HEARING
The case was taken up for preliminary hearing on DT. 27.06.2018, with respect to admission or rejection of the application when Sh. Ashok kumar Mishra, Advocate along with Sh. Surender Singh, Director appeared and made contentions as per details in their ARA. The jurisdictional officer, Sh. Rajesh Surendran, Suptt. Division- Baramati Pune – II Central GST Commissionerate appeared and made written submissions.
The application was admitted and final Hearing was held on 24.07.2018, Sh. Ashok kumar Mishra, Advocate along with Sh. Surender Singh, Director appear
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whole animal carcass in frozen state. Applicant further submit that the carcass would be in different weight and sizes and there is no fix quantity and size in which these carcasses are dispatched to the Army. The said dispatches are made on the basis of weight of frozen carcass. Furthermore the consideration is charged on the basis of weight. As regard packaging and dispatch pattern it is submitted that each frozen carcass is put in LDPE Bag (Primary Packing) which is not sealed & no weight is mentioned on such LDPE Bag. Thereafter, generally one or two of such LDPE Bags are put in HDPE Bag (Secondary Packing) and no weight is mentioned on such HDPE Bag too. Hence, the invoicing is done for entire weight of the lot and no mention of weight of each bag of the lot.
The notification no.1/2017 and 2/2017 – Integrated Tax (Rate) both dated 28th June 2017and further amended by notification no 43/2017 and 44/2017- Integrated Tax (Rate) both dated 14th November, 2017 are the central point of
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packed in LDPE bags without mentioning the weight and one or two such bags further packed in HDPE bags being supplied to Army against tender shall qualify as product put up in 'unit container'. It was further held that impugned product will be covered by schedule entry 4 of the notification of 1/2017 – Integrated Tax (Rate) during the period 01/07/2017 to 13/11/2017 and schedule I of the said notification for the period from 14th November, 2017 onwards.
Accordingly they were requested to state, similarities or as the case may be dissimilarities between the facts of this ruling and the present ARA application. Applicant has given comparative analysis of facts which are not denied by the jurisdictional officer.
Comparative analysis of facts between M/S. Ahmednagar District Goat Rearing and Processing Co-operative Federation Ltd. and the applicant are as below:
Facts
Ahmednagar Goat Federation
Monrovia Agro Foods
Product and HSN Code
Frozen Goat/ Sheep-0204
Frozen Goat/ Sheep-020
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is no mentioning of brand name also.
Requirement of Army for mentioning of weight/number
During the intervening period (i.e. 2017-18) packing conditions mentioned in Terms and Conditions (i.e. RFP) given by Army required mentioning of actual weight on the Secondary packing.
In the current tender against which supplies are being made presently (From April 2018) there is no requirement from Army side regarding mentioning of weight/ number on any packing material.
It would be important to mention here that a specific letter received from Army that there is no requirement of mentioning the weight/ number of carcass packed already provided while filing written submission.
Billing Pattern
A list showing bag wise weight against each bill was being provided to Army as attachment with each invoices.
There is no such list is either made or provided to Army the total weight is mentioned on the invoice and it is not even possible to figure it out the total number of bags in respective truck
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rom 01/07/ 2017 till present and going forward whereas in case of appellant it is from 01/04/2018 till present and going forward. The product supplied in both the case is same i.e. frozen goats and sheep carcass. However in respect of packaging of the product supplied which is a crucial aspect with respect to tax liability being there or not, we find that there is a part difference. In case of applicant there is no printing or marking of weight or number of carcass packed in such bags and there is no mentioning of brand name. Further as per the tender pursuant to which impugned supplies are to take place there is no requirement from Army regarding mentioning weight or number on the packaging material. Whereas in case of M/S. Ahmednagar District Goat Rearing and Processing Co-operative Federation Ltd packaging conditions mentioned in Terms and Conditions “RFP”given by Army required mentioning of actual weight on the secondary packaging. In this regard the applicant in the present case h
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t container' has to satisfy follow conditions simultaneously-
1. Package may be large or small
2. Packaging designed to hold predetermined quantity or number
3. Such predetermined quantity or number is indicated on such package.
From the facts submitted by the applicant and as verified by the jurisdictional officer during his factory visit, we find that each package is containing different weight and no weight/number is mentioned on packages. In view of above we are convinced that impugned supply would not satisfy the requirement of the definition of 'unit container 'as found in both the notifications sited supra. In view of this, we hold that the supply of whole sheep/ goat carcass in frozen state packed in LDPE bag and further packed in HDPE bag which do not indicate any information related to weight /number of the carcass packed in such bags would tantamount to being as a product not put up in a unit container for the purpose of notification 1/2017and 2/2017- Integrated Tax (Rat
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p in unit containers
1-2017 TO 13-11-2017
12%
Deleted w.e.f 14.11.2017
1 (Schedule I)
0202, 0203, 0204, 0205, 0206, 0207, 0208, 0209, 0210
All goods [other than fresh or chilled], and put up in unit container and, –
(a) bearing a registered brand name; or
(b) bearing a brand name on which an actionable claim or enforceable right in a court of law is available (other than those where any actionable claim or enforceable right in respect of such brand name has been foregone voluntarily], subject to the conditions as in the ANNEXURE]
14-11-2017 Onwards
5%
Notification no. 2/2017 Integrated Tax (Rate) dated 28th June 2017
10
0204
Meat of' sheep or goats, fresh, chilled or frozen [other than frozen and put up in unit container]
1-7-2017 TO 13-11-2017
NIL
Deleted w.e.f 14.11.2017
9
0202, 0203,
0204, 0205,
0206, 0207,
0208, 0209,
0210
All goods [other than fresh or chilled], and put up in unit container and, –
(a) bearing a r
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ed supply is covered by notification 2/2017 – Integrated Tax (Rate) dated 28th June, 2017 as amended by serial 9 Of the notification no. 44/2017 – Integrated Tax (Rate) dated 14th November, 2017 and would be exempt from whole of GST as per this Notification.
06. In view of the deliberations as held hereinabove, we pass the order as follows:
ORDER
(Under clause (xviii) Of section 20 Of the Integrated Goods and Services Tax Act, 2017 read with section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017)
NO.GST-ARA-20/2017-18/B-83
Mumbai, dt. 04/08/2018
For reasons as discussed in the body of the order, the questions are answered thus –
Q.1 Whether the whole (Sheep/Goat) animal carcass in its natural shape in frozen state in different weight and size packed in LDPE bags without mentioning the weight and one or two such LDPE bags further packed in HDPE bags being supplied to Army by applicant against tender shall qualify a
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