CBIC vide Circular No. 153/09/2021-GST dated 17th June 2021 has clarified the following in respect of Milling of Wheat/Paddy :
- Entry No. 3A would apply to composite supply of milling of wheat and fortification thereof by miller, or of paddy into rice, only if the value of goods supplied in such composite supply (goods used for fortification, packing material etc) does not exceed 25% of the value of composite supply. It is a matter of fact as to whether the value of goods in such composite supply is up to 25% and requires ascertainment on case-to-case basis.
- A person registered only for the purpose of deduction of tax under section 51 of the CGST Act is also a registered person for the purposes of the said entry No. 26, and thus said supply to such person is also entitled for 5% rate.