Textile printing job work, Surat. A proposal for how income should be earned, invoiced and taxed — and the questions that remain open.
Three facts about how the money is actually earned. Every characterisation later in this document rests on them, so they are set out first and without gloss.
The work is performed inside the mill, on the mill's machines, on the mill's fabric. The family owns no printing plant. What is supplied is a processing service and the labour to deliver it — not the use of capital equipment.
A large part of the income is the printing master's own skill — shade matching, colour formulation, CAD. Income of that character belongs in individual hands, and the structure is built to put it there rather than to disguise it.
Compensation tracks metres of fabric processed and delivered, with rejection risk borne by the contractor. Revenue therefore follows output, not a mark-up on wages — which is what makes the HUF a principal rather than an agent.
Three parties bill the mills directly. The husband does not — his technical input is bought by the HUF as a cost of delivering the HUF's own per-metre processing service, and the mills receive a single invoice for processed fabric.
All figures under the new regime, Sec. 115BAC, for AY 2026-27. Move any slider to see the effect on every file at once, on both ceilings, and on the GST position.
| File | Basis | Gross | Deductions | Taxable | Tax | Rebate | Surcharge | Cess | Net tax | Effective % |
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Set out in order of how much of the structure depends on them. Two are genuinely unresolved and are marked as such rather than argued away.
Creative textile design is not among the professions listed in Sec. 44AA(1). Presumptive taxation under 44ADA is available only to that closed list, so her file does not fit on its face.
Two routes exist. Characterise as technical consultancy — colour formulation is applied chemistry, and "technical consultancy" is in the list. This is defensible only if the work product is genuinely technical (recipes, fastness data, formulation records) and she holds a qualification that supports it. A designer's mood board will not carry it.
Or treat it as an eligible business under Sec. 44AD at 6%. Statutorily this is more favourable than 44ADA's 50%, and it sidesteps the 44AA(1) list entirely — but declaring 6% on pure service receipts with no materials and no plant is optically aggressive, and invites the question of what business is being carried on.
The choice should be made on a written opinion, not by default. Until then this file's figures should be read as provisional.
An HUF must be funded, and how it is funded decides whether its income is taxed in its own hands at all. If the Karta transfers his own assets into the family fund, Sec. 64(2) clubs the resulting income straight back to him and the entire benefit of the separate file disappears.
Permissible sources: ancestral funds or partition proceeds; gifts from relatives who are not coparceners; or a properly documented interest-bearing loan from a member — a loan is not a transfer, so 64(2) is not engaged, provided interest is actually charged and actually paid.
The corpus must exist in a financial year preceding the year in which the business commences. Funding the HUF and billing through it in the same year is the pattern that gets examined.
Sec. 44AD does not apply to a person carrying on agency business, and GST Rule 33 excludes pure-agent recoveries from the value of supply. Both turn on the same fact: whether the HUF trades on its own account or collects on another's.
The structure answers this by making the husband's technical input a cost of the HUF's own per-metre service, not a separate supply recovered from the mills. The mills receive one invoice for processed fabric; the HUF earns a trading margin over its inputs and bears the risk of that margin.
What must hold in the documents:
— A single per-metre invoice to the mills, with no consultancy line item and no reference to the master's fee
— A positive trading margin over the sum of inputs, borne at the HUF's risk
— No privity between the mills and the husband on the work the HUF contracts for
— The husband does not separately invoice the same mills for the same work
Note what is not in issue. The personal-skill doctrine (Raj Kumar Singh Hukam Chandji) addresses an HUF claiming as family income what is really the Karta's personal earning. Here the fee is already taxed in his own hands under 44ADA — nothing is diverted to the family. Sec. 64(2) reaches transferred assets, not services. Sec. 40A(2)(b) requires a claimed deduction, and under 44AD none is claimed.
Sec. 44AD excludes any business of commission, brokerage or agency. A labour contractor who bills wages plus a margin is an agent, and would be outside the section entirely.
Per-metre pricing places the HUF as a principal: revenue tracks output delivered, and the HUF bears the wage bill whether or not the metres come, and bears the loss on rejected fabric.
The contracts must carry this, not merely the intention. They must state the rate as ₹X per metre and never as cost-plus on wages; must place rejection liability on the HUF; and must name the HUF as the employer of the crew. A single cost-plus clause anywhere in the mill agreements undoes the analysis.
The same requirement applies to the technical input leg: it must be an input cost carried at the HUF's risk, not a recovery. A zero-margin recovery would be agency on that leg regardless of how the fabric processing itself is priced. See risk 3.
The 5% entry under SAC 9988 covers job work on textile yarns and fabrics. But Notification 15/2021-CT(R) inserted the words "except services by way of dyeing or printing of the said textile products" with effect from 1 January 2022, carving printing out of the concessional entry and moving it to 12%. The September 2025 rationalisation then abolished the 12% slab and moved residual job work to 18%.
CGST has been actively investigating textile units that continue to classify transformative processes at 5%. On a turnover of ₹2.7 Cr the difference between 5% and 18% is roughly ₹35 lakh a year — larger than the entire income-tax saving the structure produces.
This must be read off the current notification text, not off commentary or trade practice. The toggle above defaults to 18% because that is the conservative reading; if 5% is correct, note that the input-credit absorption requirement rises from 1.0× to 3.6× and the headroom on the technical input fee becomes thin.
The same fact that makes the HUF a principal for 44AD makes it the employer of the crew for labour law. That brings PF, ESI, contract labour registration where thresholds are crossed, wage registers, and wages paid through bank transfer.
Mills will contractually push principal-employer liability down the chain, and will recover from the contractor whatever they are made to pay. The exposure is joint and it is retrospective.
In rupee terms this is larger than the entire tax plan, and it is not addressed by anything on this page. It should be scoped separately and probably by a specialist.
Presumptive taxation is a commitment, not an annual election. Declaring below the deemed rate in any later year bars 44AD and 44ADA for the five subsequent assessment years, and triggers compulsory books under 44AA plus audit under 44AB for each of them. A single bad year, honestly declared, costs five.
Cash flow: advance tax under the presumptive schemes is a single instalment, 100% by 15 March. There is no quarterly smoothing, and the whole family's liability falls due on one date.
Note also that non-account-payee cheques and bank drafts count as cash for the 5% test that governs the higher ceilings. The only safe instruction to the mills is NEFT/RTGS, in writing.
A business with ₹2.7 Cr of turnover declaring ₹16.2 lakh of income, while bank balances visibly accumulate across five related files, is legally correct and statistically conspicuous. Presumptive rates are a statutory concession, not a concealment, but the gap between declared income and observable cash is what selection models look for.
If any one file is selected, all of them will be examined — they are related parties with a common transaction chain. Each leg must therefore stand on its own evidence: the wife's file must survive without reference to the husband's, and the HUF's without reference to either.
Nothing here is optional if the structure is adopted. Most of it must exist before the first invoice, not be assembled after a notice. Ticks are for this session only and reset on reload.
The eight answers that decide whether this proposal proceeds as drafted, is amended, or is abandoned.