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In the present case, the principal supply is supply of purified water whereas the service component of distribution through mobile units is the ancillary service. The purified water is eligible to tax @ 18% as it is not fit for exemption under the serial no.99 of notification No. 2/2017- Central Tax (Rate) dated 28.06.2017.

Authority for Advance Ruling — Taxability on drinking water to general public in unpacked/unsealed manner – The applicant undertakes, encourages, supports and aids charitable activities in relation to poor in the areas of medical relief, education, health, vocation, livelihood and exempted under section 12A of Income Tax Act, 1961. The applicant has proposed to undertake the activity of providing pure and safe Drinking Water at an affordable cost for the under privileged people in villages, where clean and potable drinking water is not available. The applicant sought an advance ruling as to whether supply of drinking water to general public in unpacked/unsealed manner through dispensers/mobile tankers by a charitable organisation at a concessional rate is covered under exemption of GST as per SI. No 99 of Notification 02/2017-CTR dated 28/06/2017. Held that:- The Hon’ble Authority for Advance Ruling held that the said supply is not covered under exemption as explained supra and taxable @ 18% Vide Notification No.1/2017-CTR dated, 28th June, 2017 as amended.
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