Advance Ruling— In the instant case, the applicant seeking advance ruling regarding-

a) Whether Jal Jeevan Mission is correct in classifying the services of (M/s. Call me services) provided to the government entities as exempted services?

b) Whether the services are exempt under Notification No.12/2017 Central Tax (Rate) dated 28.06.2017.

The applicant has sought ruling as to whether the manpower supply services provided to them by their service provider viz. M/s. Call me services is exempted services as per Notification No.12/2017 Central Tax (Rate)dated 28.06.2017.

The applicant has sought for a ruling as a recipient of service. The advance ruling mechanism under GST does not envisage giving a ruling to a recipient of supply of goods or services or both about the said supply at supplier end.

Here the applicant is the recipient of service and is seeking a ruling on the tax liability of a transaction made by the supplier of service.

This authority would like to make it clear that the said M/s Call me services, service provider of the applicant is well within its rights to seek an advance ruling from the jurisdictional authority, as to whether the services supplied by them to the applicant is exigible to tax. 

Held that— The ruling so sought by the applicant, on the issue of taxability of services provided by the service provider to the applicant cannot be answered owing to it being out of the scope of “advance ruling” as stipulated under Section 95(a) of CGST Act, 2017 read with Section 97(2) of the Act.