Page 124 - GSTL_23rd July 2020_Vol 38_Part 4

490 GST LAW TIMES [ Vol. 38
6. Industrial Extension Bureau, Promotion of state for commerce and in-
Gujarat dustry
7. Sardar Sarovar Nigam Limited Water harvesting and distribution of wa-
ter and electricity in western India.
8. Gujarat State Nagrikpurvatha Procurement, storage, distribution of food
Limited grains, edible oils, sugar, pulses, refined
iodised salt for the requirement of public
distribution system.

The applicant has also stated that in case of pure services provided to
private corporate and organizations like M/s. Mahi Milk Producer Company
Ltd. and M/s. N.G. Patel Finlease Pvt. Ltd., they are paying GST on services pro-
vided and have also submitted copies of work orders.
10. The applicant has concluded his submission by stating that he is of
the view that exemption mentioned in Notification No. 12/2017-Central Tax
(Rate) and Notification No. 12/2017-State Tax (Rate) shall be available to the ser-
vices provided by the applicant on the following work order and GST shall be
leviable at NIL rate of tax on supply of pure service made to State Government,
Governmental Authority, Governmental Entity and Local Authority.

Sr. Name of party Amount Constitution of party
No. (Rs.)
1. Coast Guard Region (NW) 72,00204/- Central Government
2. Collector of Ahmedabad, Bhav- 1,03,70,590/- Gujarat State Government
nagar, Godhara and Dwarka
3. Bhavnagar Forest Department 48,689/- Gujarat State Government
4. Jilla Panchayat, Mehsana 1,60,983/- Local Authority
5. Chief Officer of Ahmedabad 11,60,992/- Local Authority
and Mehsana Municipal Corpo-
ration
6. Industrial Extension Bureau, 3,60,248/- Governmental Authority
Gujarat
7. Sardar Sarovar Nigam Limited 65,62,501/- Governmental Authority
8. Gujarat State Nagrikpurvatha 1,63,574/- Governmental Authority
Limited
9. Chief Engineer, PGVCL 2,64,00,693/- Limited Company

Discussion & findings
11. We have considered the submissions made by the applicant in their
application for advance ruling as well as at the time of personal hearing. The is-
sue involved in this case is whether applicant is eligible to claim exemption bene-
fit under Sr. No. 3 of Notification No. 12/2017-Central Tax (Rate), dated 28-6-
2017 and Notification No. 12/2017-State Tax (Rate), dated 30-6-2017 for pure ser-
vices (supply of manpower, security service) provided to Central Government,
State Government, Local Authorities, Governmental Authorities and Govern-
ment Entities. As per the submission given by the applicant they are providing
services of manpower supply/security services to the following entities :

GST LAW TIMES  23rd July 2020  124