AAR Holds Semen Sorting Services for Bovine Breeding Exempt from GST

The applicant, M/s Jiva Sciences Private Limited, sought an advance ruling regarding the GST applicability and classification of “Semen Sorting Services.” The applicant provides highly specialised services involving the sorting of bovine semen to ensure a higher probability of female offspring, which is a critical service for the dairy and agricultural sectors.

The applicant contended that since semen doses themselves are exempt from GST, the processing services that enhance the quality and utility of the semen for agricultural purposes should also be eligible for exemption.

Main Issues: Whether “Semen Sorting Services” qualify as an exempt service under GST, similar to the exemption granted to semen doses and whether these services can be specifically classified under Service Accounting Code (SAC) 9986.

AAR’s Ruling: The Authority for Advance Ruling (AAR) ruled in favor of the applicant, holding that “Semen Sorting Services” are EXEMPT from GST. The Authority observed that Heading 9986 specifically covers services related to agriculture, livestock, and animal husbandry.

The AAR noted that the process of sorting semen is an integral part of livestock breeding and enhancement, directly supporting the primary agricultural activity of dairy farming. Furthermore, the Authority confirmed that SAC 9986 is the most specific and appropriate classification for these services. Since the services are categorized under agricultural support, they fall within the scope of exemption notifications issued for the sector.

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