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The activities undertaken by the applicant do not constitute supply of ‘pure services’ as it involves significant use of goods/materials.

Shanti Prime Publication Pvt. Ltd. Levy of GST — In the instant case, applicant is seeking an Advance Ruling on the applicability of Entry No. 3 of Notification No.12/2017-Central Tax to the services provided by them by way of providing energy saving street lighting services including OM of the street lighting installations to Bhubaneswar Municipal Corporation (BMC).

Held that— The services provided by the applicant by way of providing energy efficient street lighting services including 0M of the street lighting infrastructure during the contracted period to Bhubaneswar Municipal Corporation (BMC) do not constitute supply of pure services as it involves significant use of goods/materials with stipulation to transfer the total business assets to BMC at the end of the contract period. The benefit of exemption from tax in terms of S 1.3 of the notification No.12/2017-Central Tax (Rate), dated 28.06.2017 is not available to the applicant.Super Wealth Financial Enterprises (P) Ltd., In Re…. [2018] 5 TAXLOK.COM 024 (AAR-Odisha)