Order Date: 12 August 2022

Facts-

• The Applicant, M/s. Avani Infosoft Private Limited entered into a service contract with M/s Isha Outreach, a public charitable trust, Coimbatore to provide agricultural extension services for tree based agriculture to the farmers of Cauvery River Basin.
• The applicant, under the service contract, will appoint Mara Mitras who are Agriculture Extension Workers (AEW) for providing agricultural extension services, including but not limited to farmers education and training with regard to agroforestry by applying scientific research and knowledge. Isha Outreach trains mara mitras, who use a specially curated state of the art Information Technology platform through which they disseminate technical and scientific information on how to grow timber, horticulture and sericulture trees on their land.

Issue-

• Whether the services being provided by the applicant to the service contract between the applicant and M/s. Isha Outreach is exempt under entry no.57 of Notification No.9/2017?

Order-

• The Authorities observed that as per Explanation 2 (C) appended to the Notification No.9/2017-Integrated Tax (Rate) dated 28.06.2017, the term "agricultural extension" is defined to mean application of scientific research and knowledge to agricultural practices through farmer education or training. 
• In the instant case, the applicant, through mara mitras, provides education and training to the farmers for cultivation of plants / trees, by applying scientific research and knowledge. All the other activities of the applicant carried out through mara mitras from selection of saplings to assisting in transportation & planting, to monitoring the survival of plants are related to agricultural extension activity. Thus, the services of the applicant are covered under agricultural extension services.
• The Authorities held that the services are exempted in terms of entry no.57 of Notification No. 9/2017-Integrated Tax (Rate) dated 28.06.2017.