2018 (10) TMI 1244 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – 2018 (18) G. S. T. L. 489 (A. A. R. – GST) – Levy of GST – whole (Sheep/Goat) animal carcass in its natural shape in frozen state in different weight and size packed in LDPE bags – supply to Army by applicant against tender – weight not mentioned – Scope of unit container – slaughtering and processing of sheep/ goat meat and supplies these products to army against tender – N/N. 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.
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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 as product put up in “unit container”?
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Held that:- This authority has alrea
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arity with the facts of the present case.
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From the facts submitted by the applicant and ascertained and vetted by jurisdictional officer by paying visit to the factory we find that the facts of the present case are partly different from the facts in the case of M/s. Ahmednagar District Goat Rearing and Processing Co-operative Federation Ltd. – To summarize the facts we find that the period in case of ARA ruling is from 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.
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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
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egrated Tax (Rate) dated 28th June, 2017.
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Whether the products as mentioned in query 1 shall be taxable under GST as per entry no. 4 of schedule II of the Notification no. 1/2017-lntegrated Tax (Rate) dated 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? – Held that:- The period relevant in respect of present application for Advance Ruling as stated by the applicant is from 1st April, 2018 till present and continuing period. We therefore restrict ourselves to the entry as is applicable for the period from 1st April, 2018.
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The supply of whole sheep/ goat carcass in frozen state packed in LDPE bag
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mended by serial no.9 of the Notification no.44/2017 – Integrated Tax (Rate) dated 14th November 2017 and would be exempt from whole of GST.
– GST-ARA-20/2017-18/B-83 Dated:- 4-8-2018 – 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 further packed in HDPE bags being supplied to Army by applicant against tender shall qualify as
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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) which is not sealed & no weight is mentioned on such LDPE Bag, Thereafter, generally one or
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ption 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 of the above-mentioned notification reveals that GST is chargeable only when the frozen meat is put up in unit containers . ii
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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 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
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rozen: 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/ Supply agency service 00440060 15% 2. Storage and warehousing services 00440193 15% Statement containing the Applicant Interpretation of Law and submission on issue on which Advance Ruling is sought 1. Section 9 of the Central Goods and Services Tax Act 2017 9. (1) Subject to the provisions of
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f 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 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] 5. W.e.f 15th November, 2017 onwards, Schedule I of the Notification No 43/2017-lntegrated Tax (Rate) dated 14th November 2017 deals with the products whi
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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 as in the ANNEXURE I] ; 8. Conditions for Taxability:- A conjoint reading of the extracts of the above-mentioned notifications reveals that GST is chargeable subject to fulfillment of conditions as tabulated below. w.e.f. from 1st July, 2017 till 14th November, 2017. Must be frozen Must be packed in unit container W.e.f from 15th November, 2017 onwards Must be
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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 commodity i.e. a determinate quantity of goods contained therein. It should be designed to contain such determinate quantity of units of goods. 11.2 In this background, let us analyses the meaning & scope of the term unit container . 11.3 The interpretation of the expression unit container has been a vexed issue in the context of Central Excise law as under the excise regime prevailing prior to GST.
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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 short unit container means a container, whether large or small, designed to hold a pre-determined quantity or number which the manufacturer wishes to sell whether to a wholesale or retail dealer or to another manufacture. 11.7 In this background, in the context of old Central Excise Tariff, reference is placed on the following observations of the Special Bench of the Hon ble CEGAT while interpreting the term unit container
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mon 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 like, as they are ordinarily sold in the market, are packed in containers which contain a specific and clearly marked quantity of the goods. The quantity may vary according to the product and the manufacturer, but even then there are many standard quantities common to different manufacturers, such as 100 gms, 500 gms, 1 kg, 100 ml, 200 ml and 500 ml. Such products are sold in what may appropriately be called unit containers which can convenien
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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 contents as put in a unit container. Accordingly, the goods in question are not classifiable under sub-heading 2001.10 but they are classifiable under sub-heading 2001.90. 11.11 Relying on the above case law, the tribunal in the case of MP Vegetable Fruit Products v/s Collector of Central Excise, Raipur, 1995 (76) E.LT. 393 (Tribunal) =1995 (1) TMI 155 – CEGAT, NEW DELHI, held that jerry cans of tomato puree of 35 litre capacity being supplied to manufacturers o
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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 predetermined capacity, it must have so provided specifically. Therefore, the words unit container have to be interpreted in such a manner so as to include not only small but also large containers. That the sale of pasta products in the big bags knows as LDPE and HDPE cannot be said to be a sale of bulk in loose as these bags contained fixed quantity of the product for sale to the distributor/ customers. 11.15 Similar view was observed in the decision of the Tribunal in the case of Su
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antity 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 the sale of a product in big bags such LDPE and HDPE sacks cannot be said to be a sale of bulk in loose but would be a unit container where these bags contain pre-determined quantity of the product for sale to the distributor/customers. However, where such bags don t contain a pre-determined quantity, the same will not qualify as unit container. For instance in the case of CCE vs. Shalimar Super Foods [2007 (210) ELT 695 (Tri. – Mumbai) =2006 (11) TMI 56 – CESTAT, MUMBAI, the tribunal held that meat ar
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r 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 carcasses packed in the LDPE sacks and HDPE sacks would be in different weight and sizes. Further, we are also given to understand that there is no fixed quantity and size in which these carcasses are dispatched to the Army against tender. The said dispatches are made on the basis of the actual weight of the frozen carcasses. Furthermore, the consideration is charged by Monrovia Agro Foods from the Army on the basis of the weight. Therefore, there is no doubt that the said LDPE/ HDPE bags i.e., primary as well a
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nt 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 light of the discussion contained in Para 11.1 to Para 11.10, we are of the view that despatches made by the supplier in LOPE/ HDPE bags i.e. both primary as well as secondary will not be liable to tax under GST. 03. CONTENTION – AS PER THE CONCERNED OFFICER The submission, as reproduced verbatim, could be seen thus- Question 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 LOPE bags further packed
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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 submitted that the packed material is weighed as per demand and loaded in refrigerated vehicle for dispatch. For example if Anny Demand is 500kgs then the total is weighed and no of bags are noted and individual bags are not weighed and the sticker affixed not carry any registered Brand Name (Annexure-II). The tax payer also furnished a Certificate issued by the Colonel, Hdqrs Southern Command, dated 28.05.2018 (Annexure-III) certifying that the net weight/Nos of the frozen meat supplied is not required to be mentioned on the packing. The packing sticker a
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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 Chapter Sub Heading 0204. As regarding the rate of tax applicable, reference is made to the Entry No: 4 of Schedule-II in Notification no. 1/2017-lntegrated Tax (Rate) dated 28th June 2017 which is reproduced as under: 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 Accordingly the product attracts tax at the rate of12% if the same is put up in unit containers. Ongoing through the Explanation given in the notification and the comments given against Question
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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 shape in frozen state of different weight and size were packed in LDPE bags. Further a Sticker is affixed on the said bag titled Meat Dressed Frozen and contains the name and address of the Tax Payer, Batch no:, Production Date and storage instructions and a marking FOR DEFENCE SERVICE ONLY . There is no mention of weight/ quantity on the said Sticker. It is found that the said package was again packed in another LDPE bags without any markings. Photographs of a sample package and the sticker affixed on the said packages is attached herewith for reference. It was also made to und
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ocate 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 appeared made written submissions. The jurisdictional officer, Sh. Rajesh Surendran, Suptt. Division- Baramati, Pune – II Central GST Commissionerate appeared and stated that they are making submissions with respect to verification part. 05. OBSERVATIONS We have perused the records on file and gone through the facts of the case and the submissions made by the applicant and the department. The written contentions was submitted by the applicant and jurisdictional officer are examined and considered, on this issue. The applicant is registered person under GST and is engaged in slaughtering and
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PE 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 discussion, In Short, if the impugned supply is covered by the description of goods as per notification no. 2/2017 – Integrated Tax (Rate) both dated 28th June, 2017 as amended by notification 44/2017 – Integrated Tax (Rate) both dated 14th November, 2017 then the said supply is exempt from whole of GST. Applicant submits that as per above notification goods are not put up in a unit container and are also not bearing a brand name and hence benefit of notification is available in their case. During the course of hearing the applicant as well as jurisdictional officer was informed that t
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esent 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-0204 Period Relevant to Application for Advance Ruling 1st July, 2017 till Present and going forward 1st April, 2018 till Present and going forward Product Supplied to Army Meat Frozen Goat/Sheep in whole carcass From April 2018 Onwards, Meat Frozen Goat/Sheep in whole carcass. Packaging and Marking Pattern Each Frozen carcass is put in LDPE bag (Primary Packing) which is not sealed and no weight is mentioned on such LDPE bag. Thereafter, such LDPE bags are put in HDPE bag (Secondary Packing) and the weight of the Carcass is mentioned by marker. Each bag bears the different weight as meat carcass ca
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rcass 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 or weight of carcass/number put in any bag. Basis of Consideration The consideration is charged on the basis of weight of the meat supplied and number of carcass have no number of carcass have no commercial relevance. The consideration is charged on the basis of weight of the meat supplied and number of carcass have commercial relevance. Now we have been called on to find out whether the facts mentioned above in respect of M/S Ahmednagar District Goat Rearing and Processing Cooperative Federation Limited as presented at the time of proceedings in that case, have any similarity With the facts of the present case.
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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 has submitted letter dated 28/05/2017 issued by Col. S. HQ Southern Command Pune with following declaration- It is certified that chilled/frozen chicken/meat is supplied to the Army by various firms through Annual Contracts. As per order on the subject, the net weight / numbers of the item is not required to be mentioned on the packaging Thus the issue before us is whether such supply is covered by the expressions unit container as defined in the notifications mentioned. The expression unit container as defined in the notification is as below: Explanation- for the purpose of this schedule (Notification 1/2017 and 2/201
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ld 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 (Rate) dated 28th June, 2017. Question 2 Whether the products as mentioned in query 1 shall be taxable under GST as per entry no. 4 of schedule II of the Notification no. 1/2017- Integrated Tax (Rate) dated 28th June 2017 up to 14th November 2017 and thereafter as per entry no. I 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? Before we an
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hilled 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 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 I] 14-11-2017 ONWARDS NIL The period relevant in respect of present application for Advance Ruling as stated by the applicant is from 1st April, 2018 till present and continuing period. We therefore restrict ourselves to the entry as is applicable for the period from 1st April, 2018. We have already held that the supply of whole sheep/ goat carcass in frozen state packed in LDPE bag and further packed in HDPE bag which do not i
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l 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 as product put up in unit container ? A.1 Answered in the negative. Q.2 Whether the products as mentioned in query 1 shall be taxable under GST as per entry no. 4 of schedule II of the Notification no. 1/2017- Integrated Tax (Rate) dated 28th June 2017 upto 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 upto 14th November 2017 and thereafter as per entry no. 9 Of the Notification No. 44/2017-lntegrated Tax (Rate) dated 14th November 2017? A.2. The impugned product would be covered by notification 2/2017 – Integrated Tax (Rate) dated 28th Jun
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