Tamil Nadu GST Advance Ruling TN/112/AAR/2023 Withdrawal Explained
The Authority for Advance Ruling allowed the applicant to withdraw their request, meaning no decision was made on job work classification.
- Ruling
- Advance Ruling No.112/AAR/2023 Dated:10.11.2023
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- Butterfly Gandhimathi Appliances Limited requested a ruling on packing goods.
- The company asked if sending goods for packing qualifies as job work.
- The applicant later requested to withdraw the application entirely.
- The Authority granted the withdrawal without issuing a decision on the merits.
In short
The company asked the Tamil Nadu Authority for Advance Ruling (AAR) whether sending finished goods to a vendor for packing into combi-packs counts as job work or a taxable supply under the Goods and Services Tax (GST) law. Before the authority could decide, the company asked to withdraw its application. Because the request was withdrawn, the authority did not provide any guidance or interpretation on how these packing operations should be treated for tax purposes.
What has changed
How it worked before
Businesses often face uncertainty regarding whether specific outsourced activities, like packing or assembly, qualify for the GST job work exemption or must be treated as a taxable supply of goods.
What has changed
Nothing has changed. Because the application was withdrawn, this order does not provide a legal precedent or a new interpretation of GST rules for packing or job work.
Who this affects
Manufacturers or traders who outsource packing, assembly, or finishing services to third-party vendors and are unsure if these arrangements qualify as job work.
What you should do
Do not rely on this order for your own tax planning. An advance ruling is only binding on the business that requested it and its specific tax officer; since this case was withdrawn, it offers no guidance to other businesses at all.
If you do nothing
If you assume this order supports a specific tax position, you risk misclassifying your transactions. A tax officer may disagree with your interpretation, leading to demands for unpaid tax, interest, and penalties. Always seek professional advice based on your specific facts rather than relying on withdrawn or irrelevant rulings.
The terms explained
- Job work
- Any treatment or process undertaken by a person on goods belonging to another registered person.
- Advance ruling
- A written decision provided by tax authorities to a business to clarify how GST laws apply to a specific transaction.
- Taxable supply
- Any sale or transfer of goods or services that is subject to GST under the law.
The ruling in detail
Authority for Advance Ruling
M/s BUTTERFLY GANDHIMATHI APPLIANCES LIMITED
Advance Ruling No.112/AAR/2023 Dated:10.11.2023 · Tamil Nadu
Questions before the authority
- Whether sending finished goods for the purpose of packing in combi-packs by another registered vendor to be returned to us for eventual taxable supply, tantamount to taxable supply in their hands(at the time of sending for packing) or whether such sending can be treated as sending for jobwork.
Facts
The applicant is a manufacturer of domestic appliances and intended to send finished goods to a vendor for packing into combi-packs. They sought a ruling on whether this activity qualifies as job work under the GST law or constitutes a taxable supply. The applicant subsequently requested to withdraw the application as the subject transaction was no longer required.
Ruling
The Authority for Advance Ruling allowed the applicant to withdraw the application. Consequently, no ruling was provided on the merits of the questions raised.
Reasoning
The applicant submitted a letter dated 02.11.2023 requesting the withdrawal of their application. The Authority considered this request and decided to treat the application as withdrawn without examining the merits or detailed facts of the case. No specific provisions were interpreted as the matter was disposed of based on the applicant's request.
Provisions relied on
- Section 98(4) of the CGST Act, 2017
- Section 98(4) of the TNGST Act, 2017
For the practitioner
This order provides no guidance on the classification of job work versus taxable supply for combi-pack operations. It serves only as a procedural record of an **application withdrawal**. Practitioners should note that this ruling does not establish a precedent for similar business arrangements.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/112_butterfly_gandhimathi.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
About Patron Accounting LLP
Patron Accounting LLP is a CA and CS-led accounting and compliance firm that has been working with businesses across India since 2019. We handle the work that keeps a company correct with every department it answers to: day-to-day bookkeeping and accounting, GST registration and returns, income tax filing and assessments, TDS, payroll and PF/ESI, company and LLP incorporation, ROC and MCA compliance, statutory and internal audit, physical stock and inventory audits, trademark and other registrations, and the certificates and reports that banks, buyers and regulators ask for.
Our clients range from a first proprietorship registering for GST to established companies running operations across several states. Much of our work is exactly this: reading what a department has published and telling a business, in plain terms, whether it changes anything for them.
We operate from five offices and serve clients across the rest of India remotely:
- Pune (HQ): RTC Silver, B4-708, Sai Satyam Park, Wagholi, Pune, Maharashtra 412207
- Mumbai: 104, Rajshila Building, 597 J.S.S. Road, Marine Lines, Mumbai 400002
- Delhi: 3rd Floor, B-6/154-155, Sector 5, Rohini, Delhi 110085
- Gurugram: Pioneer Urban Square, B109, Golf Course Ext Road, Sector 62, Gurugram 122098
- Ahmedabad: Phoenix Tower, 1107, near Commerce Six Road, Drive In Road, Navrangpura, Ahmedabad, Gujarat 380009
If anything on this page affects you and you would like somebody to look at your own position, we are glad to help. Call +91 94594 56700, write to sales@patronaccounting.com, or visit patronaccounting.com. The first conversation costs nothing.