Authority for Advance Ruling (Karnataka): In a case relating to whether the services, including education and training to farmers with regard to agro forestry through scientific research and knowledge are covered under ‘Agricultural extension Services’, and whether the applicant can avail tax exemption on such services, the two-member bench of M.P Ravi Prasad (State) and T. Kiran Reddy (Central) observed that the services being provided by the applicant are covered under ‘agricultural extension services’, thus, exempted from tax.
The Authority noted that the applicant provides services by appointing Mara Mitras- the Agriculture Extension Workers (AEW), to educate and train farmers regarding agro forestry by applying scientific research and knowledge. Further, the applicant’s activity includes promotion of tree-based agriculture, farmer enrolment, conducting proof of plant surveys and survival surveys, and inventory tracking at nurseries etc. Moreover, the applicant allocates the Mara Mitras to the talukas or gram panchayat, where they visit the farmers to enroll them in agroforestry schemes, register demand for saplings and document the data etc.
The Authority observed that, from the scope of work it is seen that the applicant through their Mara Mitras not only educate and train farmers regarding agro forestry through scientific research and knowledge but are also involved in hand holding the farmers from recording demand for saplings, picking up the saplings from the nurseries to their plantation, and also, monitor post plantation survival.
The Authority further noted that the term ‘agricultural extension’ is defined as “application of scientific research and knowledge to agricultural practices through farmer education or training”, and observed that the applicant through Mara Mitras also provides services such as selection of saplings, assistance in transportation, monitoring the survival of plants etc that are related to agricultural extension activity, hence, it ruled that the services being provided by the applicant are covered under agricultural extension services, thus, exempted from tax as per Entry No.57 of Notification No. 9/2017 of the Integrated Tax Rate.
[Avani Infosft Private Ltd., In Re, 2022 SCC OnLine Kar AAR-GST 13, decided on 12-08-2022]
Advocates who appeared in this case :
Mallikarjun Patil, Advocate, Present for the applicant.