DGGI Investigations on Flour Mills; GST Implications and Way Forward

DGGI Investigations on Flour Mills; GST Implications and Way Forward --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Taxmann’s ‘Indirect Tax Research & Advisory’ Team July, 2021

Contents Executive Summary ................................................................................................................................................................................................................................. 1 1.

Introduction ...................................................................................................................................................................................................................................... 2

2.

Background of Public Distribution Scheme and Relevant Facts ........................................................................................................................................... 3 Step I - Procurement of wheat and its transportation to Flour Mills ..................................................................................................................................................... 3 Step II - Processing at Flour Mills (Wheat in to Atta) & Transportation to Warehouse/Ration Shops ................................................................................................ 3 Step III – Sale of Wheat from Ration Shops to Beneficiaries ................................................................................................................................................................... 4

3.

Issues for consideration.................................................................................................................................................................................................................. 6

4.

Analysis & Our Comments ............................................................................................................................................................................................................ 7 4.1.

Nature of Supply....................................................................................................................................................................................................................... 7

4.2.

Valuation of the supply ......................................................................................................................................................................................................... 10

4.3.

Exemption to Flour Mills under PDS Scheme .................................................................................................................................................................... 17

4.4.

GST rate where exemption is not available ....................................................................................................................................................................... 20

4.5.

Way forward for the Flour Mills.......................................................................................................................................................................................... 21

About Taxmann ..................................................................................................................................................................................................................................... 22 About Taxmann’s Research and Advisory Team ............................................................................................................................................................................ 23 About Authors........................................................................................................................................................................................................................................ 24

Executive Summary 

Activity of Conversion of wheat in to flour qualify as composite supply of services wherein principal supply is conversion/crushing services



Wheat under public distribution system pertains to the State Government on which processing is done by the Flour Mills, thus it qualify as job work under GST



Value of supply shall be the cash consideration and the other non-monetary consideration (Gunny Bags, etc.) received by the Flour Mills



Exemption would be available where the value of goods in the composite supply does not exceed 25% of the value of composite supply



GST shall be applicable at the rate of 5% under heading 9988 (where exemption is not available)



GST paid at the rate of 18% by the Flour Mills during investigation stage can be claimed as refund along with interest

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1.

Introduction



Investigations were initiated by the Directorate General of GST Intelligence (hereinafter referred as ‘DGGI’) on various Flour mills operating under Public Distribution System (hereinafter referred as ‘PDS Scheme’) in the State of West Bengal during the last year. It was alleged that these mills were not paying GST as per the requirement of the GST legislation.



Flour Mills paid GST at the rate of 18% during the investigation stage as authorities were not agreeing with the position that the activity of conversion of wheat in to flour qualify as Job work under the GST legislation.



Considering the various issues faced by the Flour Mills, the Central Board of Indirect Taxes and Customs (hereinafter referred as ‘CBIC’) has recently issued a Circular1 clarifying few issues relating to the GST applicability on the impugned transaction.



This document prepared by the Taxmann’s Research & Advisory (Indirect Tax) Team analyses the GST Implications on the services provided by the Flour Mills operating in the State of West Bengal under the PDS scheme and a way forward for them. The document would also be relevant for the other Flour Mills operating in other States as generally the PDS scheme operates in similar way in other States as well. Few issues relating to Rice Mills are also similar is nature, therefore, few interpretations followed in this document would also be relevant for them as well.

1

153/05/2021-GST dated June 17, 2021

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2.

Background of Public Distribution Scheme and Relevant Facts



The Essential Commodities Act, 1955 provides for the control of the production, supply and distribution relating to certain essential commodities. Under this law, each of the State Government issues its own PDS (Maintenance and Control) orders.



The PDS scheme serves poor section of society by providing them the qualitative food grains, etc. at the subsidized prices from the ‘Fair Price Shops’ (generally referred as ‘Ration Shops’). The PDS scheme (specific to West Bengal) inter-alia operates as under: Step I - Procurement of wheat and its transportation to Flour Mills



The Food Corporation of India (hereinafter referred as ‘FCI’) procures the wheat from the farmers at the Minimum Support Price as decided by the Central Government. This in turn purchased by the State Governments which later allocated to the empanelled Flour Mills for processing. The State Government transports the wheat to Flour Mills in the ‘Gunny Bags’.

Step II - Processing at Flour Mills (Wheat in to Atta) & Transportation to Warehouse/Ration Shops



The Flour Mills processes the wheat as per the requirement of the State Government. The processing activities includes conversion of wheat in to flour, fortification (adding specified nutrients such as Vitamin A, Iron, etc.), packaging, etc.

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

The agreement between the State Government and Flour Mills including the guidelines issued in context of PDS scheme provides that the out-turn ratio of wheat in to flour should be 95%. In other words, for every 100 Kgs of wheat, the processed flour must be at least 95 Kgs.



The remaining 5% pertains to debranning (4%) and refractors (1%) which are the by-products in this whole processing activity. The by-products generated during this process is generally sold in the market by the Flour Mills.



After processing the wheat as per the agreement and guidelines, the distributors/transporters/flour mills takes the packed fortified flour and transports it either to the State Government’s warehouses or to the Ration Shops directly.

Step III – Sale of Wheat from Ration Shops to Beneficiaries



The beneficiaries of PDS scheme (such as BPL card holders, etc.) purchases the wheat from these Ration Shops at subsidized prices.

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

In all the above steps, the State Government (specific to West Bengal) incurs the expense in the following manner: Table – 1 Cost sheet of 95 KG Atta out of 100 KG wheat Sl. No. 1 2

3

4 5 

Items Purchase of 100 KG from FCI @ Rs. 200/qtl (borne by the State Government) Commission of distributors and dealers Flour Millers to be paid for crushing of 100 KG of Cost for 95 KG wheat Atta (in Rs.) A Crushing charges 90.78 B Fortification cost 10.00 C Packing Charges 50.00 D Transportation and Handling charges 28.70 E Total (A+B+C+D) 179.48 F Less: Cost of 2 gunny bags (43.00) G Net total (E - F) 136.48 Total Cost to be incurred by the State Govt. (1+2+3) Sale Price of Fortified Atta

Cost in Rs./qtl 200.00 70.00

136.48

406.48 200.00

In the above table, Sl. No. 3 is relevant for the Flour Mills, as per which one can note that these mills get the cash consideration of Rs. 136.48 per quintal. The gunny bags mentioned above are also sold by the Flour Mills in the open market. The market value of 2 bags are estimated by the State Government at Rs. 43.

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3.

Issues for consideration



In the above backdrop, in view of the DGGI investigations, one may have the following questions: a)

What is the nature of activity carried out by the Flour Mills operating under the PDS scheme?

b)

What would be the value of supply including the treatment of Gunny Bags and By-products?

c)

Whether any exemption under GST is available to the Flour Mills in respect of the impugned supply?

d)

What would be the GST Rate on impugned services (where exemption is not available)?

e)

Suggestive way forward for the Flour Mills operating under PDS Scheme

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4.

Analysis & Our Comments



GST is levied on the supply of goods or services or both. The term supply has been defined2 to include all forms of supply, such as sale, exchange, barter, etc. for a consideration in the course or furtherance of business.



Further, the GST law provides3 that where the treatment or process is applied to another person’s goods then the same would qualify as supply of services.



In the given case, the Flour Mills is engaged in the business of crushing of wheat (including the activity of fortification) in to the flour. In this regard, it receives consideration from the State Government. Therefore, the given activity would qualify as supply (of services) under GST and thus leviable to GST.

4.1. Nature of Supply 

2 3

As per the GST laws, when two or more goods and services are supplied together then such combination of supplies can either be referred as ‘Composite Supply’ or ‘Mixed Supply’. The GST law provides separate treatment for both these supplies discussed as under:

Section 7(1) of the Central Goods & Service Tax Act, 2017 (CGST, Act) Entry No 3 of Schedule II of the CGST Act

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Nature of Supply Treatment In case where a combination of goods and/or services qualify as ‘composite Composite supply’ then the treatment which is applicable to the principal supply in such Supply combination is applicable on all the other goods and/or services Mixed Supply In case where a combination of goods and/or services qualify as ‘Mixed supply’ then the treatment which is applicable to the supply which attracts the highest rate of tax in such combination is applicable on all other goods and/or services 

The GST law defines4 the term Composite Supply as under: ‘Composite supply’ means a supply made by a taxable person to a recipient consisting of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply.



Further, the principal supply is defined5 as under: ‘Principal supply’ means the supply of goods or services which constitutes the predominant element of a composite supply and to which any other supply forming part of that composite supply is ancillary

4 5

Section 2(30) of the CGST Act Section 2(90) of the CGST Act

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

In the given case, the services by the Flour Mills consists of two or more taxable supplies (such as conversion, fortification, transportation, etc.) which are naturally bundled and supplied in conjunction with each other in the ordinary course of business. In our view, in this bundle of activities, the activity of conversion of wheat in to flour is predominant activity and other activities (fortification, packaging, etc.) are ancillary to it thus the conversion activity would qualify as ‘principal supply’.



In the above backdrop, it can safely be concluded that the given set of activities would qualify as composite supply of services under the GST Legislation.

4.1-1. Impugned transaction qualify as Job Work under GST 

The GST law defines6 the term job work as an activity or a process on the goods that belongs to the other ‘registered person’.



As per the above definition, in order to qualify a transaction as job work, the following two conditions must be satisfied: (a) Goods on which activity or process is done must belong to another person (b)

6

That another person must be a registered person under GST legislation

Section 2(68) of the CGST Act, 2017

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

In the case of wheat milling activity under PDS Scheme, the wheat pertains to the State Government which is given by the District controller of Food & Supplies (hereinafter referred as ‘District Controller’) to the Flour mills for processing in to flour.



In respect of second condition, the law defines7 the meaning of the term registered person as a person who is registered under Section 25 of the CGST Act but does not include a person having a Unique Identification Number.

Section 25 (supra) provides the procedure of registration for persons who are liable to be registered under Section 22 or 24 of the CGST Act.



The District Controller (i.e. office of the State Government) is required to get registered under Section 24 of the CGST Act as a tax deductor. Therefore, the State Government in the given case is a registered person under the GST laws. The given view is also been clarified8 by the CBIC.



In the above background, it can be said that the provision of service by the flour mills to State Government qualify as Job work activity under the GST Legislation.

4.2. Valuation of the supply

7 8

Section 2(94) of the CGST Act, 2017 Para 3.2 of the Circular No. 153/09/2021-GST dated June 17, 2021

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

Under the GST laws, the value of supply on which tax is required to be paid, in general, is the transaction value of the supply of goods/services9. Transaction value means the ‘price which is paid or payable’ for the supply of goods/services. Transaction value is taken as the price of supply where the parties are not related to each other and price is the only consideration.

Gunny Bags are non-monetary consideration



The Government allocates the wheat to the Flour Mills in the gunny bags. The Flour Mills sell these bags in the open market.



GST is levied on the consideration that has been charged by the supplier for the supply. Under the GST law, the term consideration has been defined10 to include a payment made or to be made either in money or otherwise for the supply of goods or services, whether by the recipient or by any other person.



The guidelines issued under PDS scheme and agreement between the State Government and Flour Mills do not provide anything about the treatment of Gunny Bags (i.e. Will it be a property of the Flour Mills or the State Government).



However, the Department of Food & Supplies of West Bengal in a memo (i.e. Table 1 covered above) dealing with the cost under the PDS scheme has covered the value of gunny bags as a non-cash consideration to the Flour Mills.

If we extract the said table then we may say that the Flour Mills receives the consideration in the below manner:

9

Section 15(1) of the CGST Act Section 2(31) of the CGST Act, 2017

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Consideration to Flour Mills Flour Mills to be paid for crushing of 100 KG Cost for 95 KG Atta of wheat (in Rs.) A Crushing charges 90.78 B Fortification cost 10.00 C Packing Charges 50.00 D Transportation and Handling charges 28.70 179.48 E Total (A+B+C+D) F Less: Cost of 2 gunny bags (43.00) 136.48 G Net total (E - F) 

The deduction of value of Gunny Bags from the value of gross consideration indicates that the Gunny bags are non-monetary consideration whose market value (as estimated by the State Government) is Rs. 43.



In this regard, one must refer the judgement of the Hon’ble Supreme Court in the case of N.M. Goel & Co. Vs Sales Tax Officer11 where it was held that when the goods for the performance of service were supplied by the recipient to the supplier and the value of goods supplied were debited or deducted from the final due amount under the contract, then such goods supplied must be treated as a part of consideration (i.e. non-monetary consideration).

11

N.M. Goel & Co. v. Sales Tax Officer, Rajnandgaon, 1990 taxmann.com 1352 (SC) [28-10-1988]

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

Thus, in the above backdrop, in our considered view, the gunny bags given by the State Government to the Flour Mills are non-cash consideration.

Treatment of By-products generated during the job work process



The agreement between the State Government and Flour Mills including the guidelines notified in respect of PDS scheme provides that the out-turn ratio12 of wheat in to flour should be 95%.The remaining 5% are by-products [i.e. debranning (4%) and refractors (1%)]. The by-products generated during the job work process is generally sold in the market by the Flour Mills.



Here it is interesting to note that the cost sheet initially notified by the West Bengal Government (as covered in Table 1 above) does not provide the treatment of By Products, however, later the State Government has issued a memo clarifying GST Implications on the Impugned transaction which has provided the following cost sheet:

12

Out-turn ratio is the ratio of output units generated from the inputs.

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Table – 2 Cost sheet of 95 KG Atta out of 100 KG wheat for AAY scheme Sl. No.

Items

1 2

Purchase of 100 KG from FCI @ Rs. 200/qtl (borne by the state government) Commission of distributors and dealers Cost for 95 KG Flour Millers to be paid for crushing of 100 KG of wheat Atta (in Rs.) A Crushing charges 90.78 B Fortification cost 10.00 C Packing Charges 50.00 D Transportation and Handling charges 28.70 Consideration from sale of Bran and refractors (4* Rs 20 Per KG E 81.00 + 1* Rs 1 Per Kg) F Total (A+B+C+D+E) 260.48 G Less: Cost of 2 gunny bags (43.00) H Less: By Products Consideration (81.00) I Net total (F – I- H) 136.48 Total Cost to be incurred by the State Govt. (1+2+3) Sale Price of Fortified Atta

3

4 5 

Cost in Rs./qtl 200.00 70.00

136.48

406.48 200.00

In the above table, at Sl. No. 3 the Food & Supply Department has provided the by-products as non-monetary consideration while determining the value of supply of the Flour Mills. It considered the market value of byPage 14 of 26

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products in the value of Composite supply. The same view has been taken by the Directorate of Commercial Taxes of West Bengal in a memo issued in this regard. 

Basis the above, one may say that the by-products can be considered as non-monetary consideration made to the Flour Mills13.

Valuation as per CGST Rules



In the given case, in addition to the cash consideration, the Flour Mills also receive the Gunny bags, etc. from the State Government in respect of the conversion activity of wheat in to flour. Therefore, it can be said that in the given case, the Flour Mills are not merely getting the cash consideration i.e. price is not a sole consideration.



Where the price is not a sole consideration, the value of supply is determined as per the valuation provisions given under the CGST Rules14.



The valuation rules provide that the value of supply of goods/services where the consideration of the supply is not wholly in monetary form (i.e. there is a non-monetary consideration), then in such cases the valuation shall be determined as per the following methods sequentially: (a) Open Market Value of goods/services so supplied

13 14

The above comments are the views of the Government and Tax Authorities.

Rule 27 to Rule 31 of the CGST Rules

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(b) Money value equivalent to the consideration not in money if known at the time of supply plus consideration in money (c) Value of supply of like kind and quality (d) Cost of supply plus 10% mark-up (e) Best Judgment method - Value of supply determined by using reasonable means consistent with principles & general provisions of Valuation 

The term ‘open market value’ of supply of goods/services has been defined15 as full value of money (excluding GST & Compensation Cess) at the time when the supply is made, where the parties are not related and price is the sole consideration.



In the given case, had the price been the sole consideration, the State Government would have paid the market value of the non-monetary consideration (i.e. Gunny bags, etc.) as declared in the cost sheet memo notified by it to the Flour Mills. Therefore, the gross value (cash value including the open market value of the Non-monetary consideration) as mentioned in the cost sheet memo can be taken as the value of supply.



Therefore, the gross value (cash value and value of non-monetary consideration) can be construed as open market value in the given case.

15

Rule 35 of the CGST Rules

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4.3. Exemption to Flour Mills under PDS Scheme 

Where the composite supply of goods/services are provided to the State Government by way of any activity in relation to any functions entrusted to Panchayat under Article 243G or to Municipality under Article 243W and value of supply of goods does not exceeds 25% of the value of the composite supply, then such composite supply is exempt16 under GST.



Thus, the above exemption would be available if the following conditions are satisfied: The supply must be a Composite supply; State Government is the recipient of the supply; Supply should be in relation to any function entrusted to a Panchayat under Article 243G or to a Municipality under Article 243W of the Constitution; and Value of supply of goods should not be more than 25% of the value of the composite supply



Each of the above points relating to impugned exemption are discussed in the below mentioned paragraphs.

4.3-1. Supply must be a Composite supply 

16

The impugned supply qualify as a composite supply of goods and services (refer para 4.1. of this document).

Sl. No. 3 & 3A of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 and Notification No. 09/2017-Integrated Tax (Rate) dated 28-06-2017

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4.3-2. Supply should be made to Government, etc. 

The service recipient in the impugned case is the State Government which gives the contract to the Flour Mills.

4.3-3. Supply is in relation to a function entrusted to a Panchayat or Municipality 

Article 243G read with the Eleventh schedule of the Constitution empowers a State to endow functions and devolve powers and responsibility to the local bodies by enacting the relevant laws. This article enables the Panchayats to function like a Self-Government for the implementation of schemes provided under the Eleventh Schedule of the Constitution. PDS scheme has been included in the Eleventh schedule of the Constitution. Thus it can be said that PDS scheme is a function entrusted to Panchayat under Article 243G of the Constitution.



Similar to Article 243G, Municipalities are entrusted with some powers, authorities, and responsibilities under Article 243W of the Constitution read with Twelfth schedule of the Constitution. The Twelfth schedule, inter alia, provides for safeguarding the interest of the weaker sections of the society. The PDS scheme serves the weaker sections of the Society (such as BPL card holders). Thus it can be said that activity of PDS scheme is a function entrusted to Municipality under Article 243W of the Constitution.



In the given case, the Flour Mills provides services to the State Government in respect of functions entrusted to Municipalities/Panchayats under the Constitution.

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4.3-4. Goods value should not exceed 25% of value of Composite supply 

The exemption would be available if the value of supply of goods in the composite supply does not exceeds 25% of the value of composite supply. Here the value of composite supply refers to the consideration paid or payable to the Flour Mills (in monetary and non-monetary form). The Flour Mills during the provision of service uses various nutrients for fortification and also uses the packaging material for packing the flour. The consideration paid for fortification and packaging activities includes the consideration for the material (i.e. goods) used as well as the services of fortification and packaging (this has also been confirmed by the Directorate of Commercial Taxes of West Bengal in its memo issued for the Flour Mills).

Treatment of nutrients used during fortification process in computing limit of 25%



The value of goods supplied in the composite supply refers to the ‘goods which are supplied by the supplier to the recipient‘. The nutrients are consumed during the fortification process and thus a view can be taken that these are not ‘supplied’ per-se. At max these nutrition can be referred as consumables in the process of job work activity.



In this regard, one may refer the meaning of the term ‘Consumable’ from the judgement of the Hon’ble Supreme Court in the case of Meridian Industries Ltd vs CCE17 where it was held that Consumable is an item that does not form part of the end product and the same gets substantially or totally consumed during the manufacturing process.

17

Meridian Industries Ltd. v. Commissioner of Central Excise [2015] 63 taxmann.com 67 (SC)

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

In the fortification process, the nutrients like vitamins, minerals, irons, etc. as per the guidelines/instructions of the State government are mixed in the wheat, which gets consumed during the conversion activity. The nutrients used during the fortification process are not supplied to the recipient. Therefore, it may not be required to be added in the calculating the limit of 25%.



Notably, the Department of Commercial Taxes of West Bengal in its communications etc. has considered the value of fortified Atta in computing the limit of 25%. In our view, these should not be required to be added.

Treatment of Packing Material in computing limit of 25%



The Flour Mills packs the fortified flour as per the guidelines/instructions issued by the State Government. The packing material can be considered as supply of goods in the composite supply. The amount paid for packaging charges consists of packing material and for the service of packing. In such case, the bifurcation should be made and only the value of packing material should be considered for determining the value of goods supplied. This may change on fact to fact basis.

4.4. GST rate where exemption is not available 

18

In a case, where exemption is not available on the impugned activity then the supply of services by the Flour Mills would be classified under the heading 9988 and the GST rate applicable18 shall be the rate of 5%.

Notification no. 11/2017- Central Tax (Rate) dated June 28, 2017

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

Notably, the argument that the impugned activity does not qualify as job work and thus rate of 18% would be applicable in our view is not correct.

4.5. Way forward for the Flour Mills 

Based on our analysis in this document, it is recommended that the Flour Mills should analyse their scenarios in order to determine the GST implications on their activity.



Further, the Flour Mills who have paid the tax at the rate of 18% during the investigation stage can file the refund claim before the tax authorities along with interest.

Note: The views expressed above are for guidance purposes and cannot be construed as legal advisory.

In case of any query/clarification, feel free to reach us at Sunil.kumar@taxmann.com

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About Taxmann 

Formed in 1960, Taxmann is the leading publisher on Tax & Corporate laws in India



We also maintain the largest and the most accurate online database on Income Tax, International Taxation, GST, Accounts & Audit, Corporate & SEBI Laws, etc.

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About Taxmann’s Research and Advisory Team 

Research & Advisory Team of Taxmann helps businesses in managing the risk related to Tax and Corporate Laws of India

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Our service portfolio comprises of Advisory, compliance checks, Advocacy support, In-House Trainings, Issue specific Research Supports, etc.

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Our team aims to work as a business advisor, bringing forth the complex matrix of different issues in a simple, understandable and executive manner

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Our team consists of Lawyers, Chartered Accountants, and Company Secretaries having vast and varied experience of working in industries and consultancy firms

Page 23 of 26 Taxmann’s Indirect Tax Research and Advisory

About Authors

Sunil holds expertise in laws relating to GST, Customs Duty, Foreign Trade Policy and other erstwhile Indirect Tax laws (such as Service Tax, VAT, etc.). Sunil has wide range of experience in multiple sectors including Food Processing, Automobile, Capital Goods, Consumer Durable, Media and Entertainment, Publications, Telecom, ITeS, etc.

Highlights  5+ years of experience in Indirect Taxation  Experience in Advisory, Health Checks, Advocacy Support, Contract Reviews, GST Implementation, etc.

Sunil Kumar (Author)

 Actively writes and speaks on various ongoing Indirect Tax issues  Formerly worked with KPMG India and Nitya Tax Associates Paras is a young enthusiastic Chartered Accountant qualified in November, 2020. He has joined Taxmann’s Indirect Tax Research & Advisory Team in April 2021. He handles Indirect Tax issues relating to various industries including Food Processing, Education, Media & Entertainment, Tourism & Hospitality, etc.

Highlights  Internship experience in Indirect Taxation in various areas including Advisory support, GST Refunds, etc.

Paras Mudgal (Co-Author)

 Interned with BDO India LLP and Singhi Chugh & Kumar  Actively works on ongoing Indirect Tax issues Page 24 of 26

Taxmann’s Indirect Tax Research and Advisory

Kriti has completed four years in BBA LLB (H) from Amity University, Uttar Pradesh. She has studies different branches of law including the Constitutional Law, Taxation Laws, etc. She has joined Taxmann Indirect Tax Research and Advisory Team as Legal Intern in June 2021.

Highlights  Actively involved in research support on various ongoing Indirect Tax issues  Possesses a very good academic background Kriti Khunger (Co-Author)

 Formerly interned with Intellect Law Offices and Pahuja Law Academy

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