GST Exemption for Semen Sorting Services Under SAC 9986
The Gujarat Authority for Advance Ruling confirmed that semen sorting services for bovine breeding are exempt from GST under SAC 9986.
- Ruling
- GUJ/GAAR/R/2026/09 dated 03/03/2026
- Dated
- 03 Mar 2026
- 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
- Semen sorting services are classified under SAC 9986.
- These services qualify for a Nil GST rate.
- The activity is considered an intermediate process for animal rearing.
In short
The company asked if their semen sorting services, which separate X and Y chromosomes in bovine semen, qualify for the same GST exemption as semen doses. The tax authority examined whether this work should be taxed as a technical service or exempted as an agricultural support service.
What has changed
How it worked before
It was unclear if these specialized sorting services were exempt or if they should be taxed as general technical or professional services.
What has changed
The authority ruled that these services fall under SAC 9986 as support services for animal husbandry. This means the service is exempt from GST, as it is an essential part of the livestock breeding process.
Who this affects
Businesses providing specialized laboratory or processing services to bovine semen stations.
An example
Imagine a company that provides specialized DNA testing for cattle breeding to improve herd quality. They might ask if their service qualifies as an agricultural support service under SAC 9986. Based on this ruling, they could argue that their work is an essential intermediate step in animal husbandry and should also be exempt from GST.
What you should do
If you provide similar services, you may use this logic to support your tax position. However, remember that an Advance Ruling only binds the company that asked and its specific tax office; it is not a law that automatically applies to your business.
If you do nothing
If you assume this ruling applies to you and stop collecting GST without a formal clarification, your local tax officer may disagree with your classification. You could face demands for unpaid tax, interest, and penalties if the department decides your service is taxable.
The terms explained
- SAC 9986
- A classification code used for support services related to agriculture, hunting, forestry, and fishing.
- Bovine
- Relating to cattle or cows.
- Artificial Insemination
- The process of introducing semen into the reproductive tract of an animal by artificial means rather than natural mating.
The ruling in detail
Authority for Advance Ruling
M/s JIVA SCIENCES PRIVATE LIMITED
GUJ/GAAR/R/2026/09 dated 03/03/2026 · Gujarat
Questions before the authority
- Whether "Semen Sorting Services" would qualify as an exempt service under GST, similar to the exemption granted to semen doses?
- Can we classify "Semen Sorting Services" under SAC code 9986?
- In the absence of a specific notification or classification, under which HSN/SAC code should "Semen Sorting Services" be categorized?
Facts
The applicant provides semen sorting services to Semen Stations by separating X and Y chromosome-bearing sperm cells from bovine semen using proprietary technology. The processed semen is returned to the Semen Stations for final packaging and distribution for artificial insemination. The applicant sought a ruling on the classification and taxability of these services.
Ruling
| Question | What the authority ruled |
|---|---|
| Exemption status | Yes, exempt from payment of GST Based on classification as support services for animal husbandry |
| Classification under SAC 9986 | Classified under SAC 9986 As an intermediate production process related to animal rearing |
| Alternative classification | Not relevant In view of answers to Question No. 1 & 2 |
The Authority ruled that the semen sorting services provided by the applicant are classified under SAC 9986 and are exempt from GST. It determined that the activity constitutes an intermediate production process related to the rearing of animals, which is covered under the relevant exemption notification. Consequently, the services do not fall under the residual category of professional and technical services.
Reasoning
The Authority reasoned that the applicant's service is an intermediate production process related to the rearing of animals, which falls under **Heading 9986**. It relied on Entry No. 24, Sl. No. (i) of **Notification No. 11/2017-Central Tax (Rate)**, which provides a Nil rate for such services. The Authority rejected the Department's contention that the service should be classified under the residual SAC 998399, noting that a specific classification takes precedence over a general one. Furthermore, it noted that the legislative intent is to exempt activities related to the artificial insemination of livestock.
Provisions relied on
- Section 2(68) of the CGST Act, 2017
- Heading 9986
- Notification No. 11/2017-Central Tax (Rate) dated June 28, 2017
- Notification No. 2/2017-CT(R) dated 28.06.2017
- Notification No. 10/2025-CT(R) dated 17.09.2025
For the practitioner
This ruling provides clarity for service providers in the bovine breeding sector, confirming that **specialized semen sorting services** qualify for the same GST exemption as semen doses. It establishes that such activities are correctly classified as **support services for animal husbandry** under SAC 9986 rather than as general technical services. Practitioners can use this to argue against the classification of similar intermediate agricultural support services under residual tax categories.
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/09_jiva_sciences_pvt_ltd_0001.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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