Classification of service— In the instant case, the applicant is seeking advance ruling regarding the taxability of the said services & input to be taken on buses and repairs and Maintenance Expenses as same is allotted with the work through Tender Process.

The Service Recipient companies BCLL, AICTSL, and JCTSL is State Govt. Company. The Service Recipient companies will be paying the service provider on the total effective run kilometre. Applicant is providing non AC buses with Drive, Fuel, Repairs and Maintenance of buses. Route of the buses & the applicable fare will be decided by service Recipient and provide the transportation services to passenger.

Held that— On a joint reading of the terms of the agreement, high court rulings, para 8 Board Circular No. 164/20/2021 - GST dated 06.10.2021. Entry No. 10 of Notification No. 11/2017 - Central Tax (Rale) and Entry No. 22 of Notification No. 12/2017-Central Tax (Rate) it appears that supply covered under the agreement entered into by the applicant with AICTSL. BCLL. JCTSL. which are state government companies as per ROCs submitted by the applicant, is covered under Entry No. 22 of Notification No. 12/2017 - Central Tax (Rate) and is an exempt services.

Once the supply is exempt, the question relating to question no. Il and III on tax and admissibility of input lax credit is redundant.