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Nirma university cannot be termed as “Governmental Authority”. Therefore the exemption provided vide Sr. No. 4 & 45 of Notification No. 12/2017-Central Tax (Rate) is not admissible.

Classification of service— The issue involved in this case is regarding admissibility or otherwise of benefit of Sr. No. 45 and Sr. No. 4 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017. The advance ruling authority examined the issue and held that the appellant does not fall under the definition of “governmental authority”. Accordingly, benefit of Sr. No. 45 and Sr. No. 4 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 is not available to appellant. Aggrieved by the aforesaid advance ruling to the extent of denial of exemption under Sr. No. 45 and Sr. No. 4 of Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017, the appellant has filed the present appeal. Held that—The appellant has been set up under the Nirma university Act, i.e. an Act of the Gujarat Legislature, therefore it falls under item (i) of the definition of “Governmental Authority”. However, the appellant has not claimed to be satisfying the condition of 90 per cent or more participation by way of equity or control. Therefore, we hold that the appellant Nirma university cannot be termed as “Governmental Authority” within the definition of the said expression under clause (zf) of para 2 of Notification No. 12/2017-Central Tax. This authority reject the appeal filed by the appellant.
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