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GST on Jewellery Regulations, Compliance, and Challenges!

The Goods and Services Tax (GST) has changed the way taxes are levied on various goods and services in India. GST on jewellery has undergone significant changes.  Let’s discuss - GST on jewellery, including the tax rates and exemptions, input tax credit, and compliance requirements.

*  Gold bars or gold jewellery fall within the definition of ‘Goods’ as per the GST law.

* Under Section 7 of the CGST Act, the supply of gold (without any job work) is considered the supply of goods.

* As per Section 8 of the CGST Act, selling gold ornaments or jewellery to the common man is a composite supply of goods and services. The gold used is considered goods and making charges or value addition is towards job work.

* Since the principal supply is the sale of gold, the GST rate of 3% shall be levied instead of 5% on the total value of jewellery, whether making charges is shown separately.

* Repair works on jewellery will be considered the making charges for which GST is charged separately at 5%.

GST on gold in various forms is discussed at length in this article. GST subsumed VAT, service tax, excise duty and several other indirect taxes charged on domestic transactions. Tax on the making charges on gold jewellery was introduced under GST. On the other hand, basic customs duty continues to be collected on the import of gold from other countries and the levy of IGST.

The GST registration threshold limits that commonly apply to normal taxpayers apply to businesses in gold mining and distribution as well. Further, the composition scheme under section 10 of the CGST Act is available to businesses selling gold.

Compliance Requirements

Jewellers are required to comply with various GST regulations to ensure that they meet their tax obligations. The compliance requirements for jewellers are as follows:

1.      Registration: Jewellers with an annual turnover of Rs. 40 lakhs or more are required to register under GST.

2.      Invoicing: Jewellers are required to issue GST-compliant invoices for all sales, including those made to unregistered persons.

3.      Filing of Returns: Jewellers are required to file monthly or quarterly GST returns, depending on their turnover.

4.      Maintenance of Records: Jewellers are required to maintain detailed records of all transactions, including purchases, sales, and expenses.

Many gold merchants or sellers or jewellers take the services of goldsmiths and specialists who carry out job work on the gold bars or gold biscuits supplied by them to make jewellery. It is considered a supply of service.

*      The goldsmiths will charge for their service known as making charges which will attract GST of 5%.

*      If these goldsmiths or specialists are not registered under GST, the gold merchant or jeweller must pay GST at 5% on a reverse charge basis.

*      Consumers who approach the goldsmiths by themselves will also have to pay 5% GST if the goldsmith is registered under GST.

GST is not charged if unregistered individuals sell gold jewellery or exchange gold ornaments to buy new ones at jewellery shops. It is not considered furtherance of business and is out of the scope of supply under GST.

However, if dealers or gold companies such as Attica Gold company, Aashraya Gold Company, or Malappuram Gold Loan, etc. purchase and sell second-hand gold jewellery, GST applies on the value of such gold calculated as per the rule 32(5) of CGST Rules, after satisfying the conditions.

GST Calculations – Example

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Input Tax Credit

Input Tax Credit (ITC) is a mechanism that allows businesses to claim credit for the GST paid on purchases that are used for business purposes. Jewellers can claim input tax credit for the GST paid on raw materials, such as gold, silver, and diamonds, as well as other expenses, such as rent, electricity, and labour.

However, ITC cannot be claimed on making charges.

e-Way bill rules for gold and its forms

From 13th September 2022, as per respective state notifications, the NIC has enabled a separate window for generating e-way bills for transporting gold, gold jewellery or precious stones.

GST Reports to be submitted

 

Return Form

Auto Generated Reports in GST Portal

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Customers walks into a Jeweller showroom and buys a Gold ornament

It is important to note that this supply is a composite supply as defined under section 2(30) comprising of supply of Gold ornament along with supply of ornament making services. Gold ornament being the principal supply, the entire value of taxable supply shall be charged @ 3% as per section 8 of the CGST Act.

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Customers walks into a Jeweller showroom and buys a Gold ornament and the Jeweller charges separately for Gold and making charges

In this case, since the consideration for both Gold and making charges have been disclosed separately in the invoice by the Jeweller, the supplies will be taxable at their respective applicable rates, i.e. Gold @ 3% and making charges @ 18%.

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Customer gives old jewellery and in return buys a Gold ornament

The old jewellery given by the Customer does not constitute supply under GST law. As per section 7 of the CGST Act, one of the essential elements of supply is furtherance of business of the person making the supply. In the instant case, sale of personal jewellery by a customer does not constitute furtherance of business by the customer. Further, as per notification no. 10/2017 (CT and UT Act), dated 28 June 2017, local purchase of second-hand goods by a registered dealer (Jeweller in this case) is exempt from tax provided the dealer pays tax at the time of resale on the value determined as per Valuation rules.

 

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Sale of old jewellery by individual to jeweller not liable to reverse charge mechanism. 

There is confusion regarding purchase of old gold jewellery by a jeweller from an Individual will be subject to GST @ 3% under reverse charge mechanism (RCM) in terms of the provisions contained in Section 9(4) of the CGST Act, 2017.

 

Clarification by Ministry of Finance on 13-07-2017.  It is therefore clarified by Government that Sale of old jewellery by an individual to a jeweller will not make the jeweller liable to pay tax under RCM on such purchases.

 

Section 9(4) of the CGST Act mandates that tax on supply of taxable goods by an unregistered supplier to a registered person will be paid by the registered under reverse charge mechanism.

 

This provision, however, must be read in combination with section 2(105) read with section 7 of the CGST Act.  Section 2 (105) defines supplier – “as a person supplying the goods or services”.  Section 7 provides that “a supply is a transaction for a consideration by a person in the course or furtherance of business”.

 

In simple words, to pay RCM on sale or supply of goods and services by unregistered dealer to registered dealer following two conditions are required to be fulfilled.  Transaction should be for consideration; Transaction should be in the course or furtherance of his business.  If both conditions are met, then RCM is to be paid by the registered supplier.

 

Here in this case even though the sale of old jewellery by an individual is for a consideration, it cannot be said to be in the course or furtherance of his business (as selling old gold jewellery is not the business of the said individual), and hence does not cover under the definition of supply. If supply has not been done, Taxable event will not arise.

 

Conclusion

Therefore, the sale of old jewellery by an individual to a jeweller will not attract GST under RCM and jeweller will not be liable to pay tax under RCM on such purchases.  Therefore, jeweller is not required to maintain any specific record for such purchase. It is advised to record as a general cash purchase without GST.

 

 

Exception:

However, if an unregistered supplier of gold ornaments sells it to registered supplier, the tax under Reverse Charge Mechanism (RCM) will apply.  The reason for the exception is the unregistered supplier is selling goods in the course or furtherance of his business and sale is for consideration i.e. fulfilling both the conditions as mentioned above

Customer sells old jewellery to the Jeweller and does not buy anything in exchange

The subject transaction does not constitute supply for the reasons discussed in case 3. Accordingly, there will be no tax implications in this case.

Customer owns gold and gets a gold bangle made from the Jeweller. The Jeweller charges making charges from the customer and pays to the Karigar

The supply of gold by the customer to the Jeweller for the purpose of making bangles will not fall under the definition of “Job work” under the GST Act due to the fact that the customer will be an individual who is not a registered person under the GST Act.

Therefore, the concessional rate of 5% of Job work in relation to gold shall not apply in the instant case and the Jeweller shall charge GST @ 18% on the making charges.

It is to be noted that the making charges paid by the Jeweller to the Karigar (job worker) will attract GST @ 5% under reverse charge (assuming that the Karigar is not a registered person).

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Job work procedure

There are provisions under the GST law which permit transfer of goods to the job worker on a challan (as per rule 55 of the CGST Rules) without payment of taxes. The details of the same are to be filed on a quarterly basis.

The Jewellers need to ensure that the movement of goods to/ from the job worker is strictly in accordance with the provisions of Rule 45 and 55 of the CGST Rules, 2017.

The GST paid will be available as ITC to the Jewellers irrespective of the fact whether the GST is paid under reverse charge or collected by the job-workers.

 

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Casual Registration under GST

"Casual taxable person'' means a person who occasionally undertakes transactions involving supply of goods or services or both in the course or furtherance of business, whether as principal, agent or in any other capacity, in a State or a Union territory where he has no fixed place of business.

*      A casual taxable person (other than those making supply of specified handicraft goods) making taxable supply in India must compulsorily take registration.

*      There is no threshold limit for registration.

*      Casual Taxable persons making supply of specified handicraft goods need to register only if their aggregate turnover crosses the threshold limit.

*      A casual taxable person cannot exercise the option to pay tax under composition levy.

*      He must apply for registration at least five days prior to commencing his business in India.

*      A casual taxable person must make an advance deposit of tax in an amount equivalent to his estimated tax liability for the period for which the registration is sought.

*      The registration certificate shall be issued electronically only after the said deposit appears in his electronic cash ledger. The amount deposited shall be credited to the electronic cash ledger of casual taxable person. On depositing the amount, an acknowledgement shall be issued electronically to the applicant in FORM GSTREG-02.

*      The casual taxable person can make taxable supplies only after the issuance of the certificate of registration. The certificate of registration shall be valid for the period specified in the application for registration or ninety days from the effective date of registration, whichever is earlier.

*      In case the casual taxable person intends to extend the period of registration indicated in his application of registration, an application in FORM GST REG-llshall be submitted electronically through the Common Portal, either directly or through a Facilitation Centre notified by the Commissioner before the end of the validity of registration granted to him.

*      The validity period of ninety days can be extended by a further period not exceeding ninety days. The extension will be allowed only on payment of the amount of an additional amount of tax equivalent to the estimated tax liability for the period for which the extension is sought.

RReturns to be submitted by Casual Person under GST

*      FORM GSTR-1            Giving the details of outward sup­plies of goods or services to

be filed on or before the tenth day of the following month.

*      FORM GSTR-2            Giving the details of inward supplies to be filed after tenth but

before the fifteenth day of the following month.

*      FORM GSTR-3            To be filed after fifteenth day but be­fore the twentieth day of

the following month.

*      FORM GSTR-3B         To be filed but before the twentieth day of the following month.

However, a casual tax person shall not be required to file any annual return as required by a normal registered taxpayer.

Refund by Casual taxable person:

The casual taxable person is eligible for the refund of any balance of the advance tax deposited by him after adjusting his tax liability. The balance advance tax deposit can be efunded only after all the returns have been furnished, in respect of the entire period for which the certificate of registration was granted to him had remained in force. The refund relating to balance in the electronic cash ledger has to be made in serial no. 14 of the last FORM GSTR-3 return required to be furnished by him (instead of FORM GST RFD0l).

Tax Rates on Jewellery

GST is levied on jewellery at different rates, depending on the type of jewellery and its value. The tax rates on jewellery are as follows:

Particulars

HSN Code

GST Rate

Gold Bars, Diamond, pearls, Jewellery, and diamond jewellery - Irrespective of the carat of gold - value of the jewellery, including synthetic or reconstructed stones, unworked or simply sawn or roughly shaped

7101, 7102

3.00%

Precious stones (other than diamonds) and semi-precious stones, whether worked or graded but not strung, mounted, or set

7103

2.50%

Ungraded precious stones (other than diamonds) and semi-precious stones, temporarily strung for convenience of transport (includes synthetic or reconstructed stones, apart from unworked or simply sawn or roughly shaped)

7104

2.50%

Silver (including silver plated with gold or platinum),
unwrought or in semi-manufactured forms, or in powder
form

7106

3.00%

Gold (including gold plated with platinum) unwrought or in semi-manufactured forms, or in powder form

7108

3.00%

Base metals or silver, clad with gold, not further worked
than semi-manufactured

7109

3.00%

Platinum, unwrought or in semi-manufactured forms, or in powder form

7110

3.00%

Base metals, silver or gold, clad with platinum, not further
worked than semi-manufactured

7111

3.00%

Articles of jewellery and parts thereof, of precious metal

7113

3.00%

Articles of goldsmiths' or silversmiths' wares and parts
thereof, of precious metal or of metal clad with precious
metal

7114

3.00%

Other articles of precious metal or of metal clad with
precious metal

7115

3.00%

Articles of natural or cultured pearls, precious or semiprecious stones (natural, synthetic, or reconstructed)

7116

3.00%

Imitation jewellery [other than bangles of lac/shellac]

7117

3.00%

Coin

7118

3.00%

Sale of old gold

 

NIL

 

 

 

Making charges of gold and diamond jewellery

 

5.00%

Goldsmith or Silversmith services

 

5.00%

Consumers who approach the goldsmiths by themselves

 

5.00%

Repair works on jewellery will be considered as making charges

 

5.00%

 

 

 

Gold Import - (including customs duty of 7.5% and 3% GST)

 

10.75%

 

 

 

Services by way of job work in relation to cut and polished diamonds, plain or studded jewellery of gold, silver and so on
 [other than diamonds] falling under Chapter
71 in the First Schedule to the Customs Tariff Act, 1975

9988

3.00%

Services by way of job work in relation to diamonds
falling under chapter 71 in the First Schedule to the
Customs Tariff Act, 1975 (51of 1975)

9988

1.50%

 

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