The Tamil Nadu Authority for Advance Ruling has held that bovine semen sorting services — the laboratory-based separation of X and Y chromosome-bearing cells from bovine semen using proprietary technology — are not classifiable under SAC 9986 (Support services to agriculture, forestry, fishing, animal husbandry) and do not qualify for exemption from GST. The services are classifiable under SAC 998349 (Other technical and scientific services nowhere else classified) and attract GST at 18%. The ruling by Members R.V. Pradhamesh Bhanu and B. Suseel Kumar in TN/51/ARA/2026 (M/s Jiva Sciences Pvt. Ltd., decided 06.08.2026) notably disagrees with the Gujarat AAR’s ruling in an identical application by the same applicant (GUJ/GAAR/R/2026/09 dated 03.03.2026), which had held the services exempt.
The AAR analysed the Explanation to Serial No. 24(i) of Notification No. 11/2017-CT (Rate), which defines ‘Support services to agriculture, forestry, fishing, animal husbandry’ to include three categories: (i) services relating to cultivation of plants and rearing of all life forms of animals, (ii) pre-conditioning/packing of fruits and vegetables, and (iii) carrying out an intermediate production process as job work in relation to rearing of animals. The AAR found that semen sorting is an independent, laboratory-based, technology-driven processing service performed on biological material that does not constitute or directly support the actual rearing, feeding, breeding management, or husbandry of livestock. It is a value-addition/testing and separation service — one step before the actual rearing process — and is therefore correctly classifiable as a scientific and technical service under HSN 9983, specifically SAC 998349.
- 2026-juristway.com-2524-AAR(Tamilnadu)-GST | AAR Tamil Nadu | TN/51/ARA/2026 | 06.08.2026