Authority for Advance Ruling, Karnataka29 July 2026

S.K. Swamy and Company, In re

For revenue

ORDER NO. KAR.ADRG/42/2026

The ruling in brief

Where applicant, a registered partnership, supplied ballast and loaded it into Railway wagons using JCB loaders without undertaking any building, construction, erection or activities connected with immovable property, such work did not meet statutory requirements for works contract and thus could not be classified as one under GST law.

Where applicant executed contract for supply of ballast and separate loading service with distinct pricing, sequential execution, separate invoices, and transfer of title to Railways before loading, such supplies were not naturally bundled or composite, but independent and liable to separate GST as per relevant classification and rate for each supply.

Where applicant provided loading services of Railway-owned ballast into wagons using mechanical loaders without engaging in transport or wagon movement, activity was essentially cargo handling, classifiable under SAC 996719, and attracted GST at 18 percent as per relevant rate notification

Provisions considered

Section 2(119) of Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017; Section 9, read with sections 2(30), 2(90) and 8, of Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017; Section 9 of Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017

This summary is for general information and is not legal advice. Read the full decision and the applicable law before relying on it.

The ruling in brief

Provisions considered

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S.K. Swamy and Company, In re

The ruling in brief

Provisions considered

S.K. Swamy and Company, In re

The ruling in brief

Provisions considered

Read the full analysis

N.S. Nayak and Sons v. State of Karnataka

Anil Annasaheb Patil v. Executive Engineer Pwd

Naganath Constructions Engineers and Contractors v. Government of Karnataka

Read the full analysis