The Gujarat Appellate Authority of Advance Ruling (AAAR) has ruled that GST payable on examination services provided to Gujarat Panchayat Service Selection Board (GPSSC).

The Gujarat Appellate Authority of Advance Ruling (AAAR) while rejecting the appeal observed that GPSSB is neither a Central Government, State Government, Union Territory or a local authority. The primary condition of the composite services having been provided to a Central Government, State Government, Union territory or local authority, not having been satisfied, is that the appellant is not eligible for the benefit of the exemption notification. 

The appellant/assessee is engaged in the manufacturing of computer forms, cut sheets, printed forms & is also engaged in trading of printers, cartridges, laptops, barcode stickers, OMR Sheet, educational booklets, etc. They provide pre and post examination services to Gujarat Public Service Commission (GPSC) and Gujarat Panchayat Service Selection Board (GPSSB).

The appellant sought the advance ruling on the issue of services provided to the GPSSB. whether the services provided to the Panchayat Service Board, amounts to services provided to the Panchayat, and covered under entries 3 and 3A, of the Notification and exempted from Goods and Service Tax?(ii)In relation to the services provided to the Gujarat Public Service Commission: Whether the services provided to the Gujarat Public Service Commission amounts to services provided to the State Government, covered under entries 3 and 3A of the Notification and exempted from Goods and Service Tax? Whether the services provided to the Gujarat Technological University amounts to services provided to the Government Entity or Government Authority, eligible for tax exemption under entry 3 and 3A of the notification?

The AAR held that the applicant is not eligible to the exemption under entry No. 3 and 34 of notification No. 12/2017-CT (R) dated 28-6-2017 as amended for supply of service to the Gujarat Panchayat Service Selection Board.

The AAR ruled that the applicant services supplied to the Gujarat Public Service Commission do not fall under the functions entrusted to a Panchayat under article 243G of the Constitution, hence applicant is not eligible to the exemption under entry No. 3 and 34 of notification No. 12/2017-CT (R) dated 28-6-2017 as amended for supply of service to the Gujarat Public Service Commission.”

The AAAR upheld the AAR’s ruling and rejected the appeal.

Ruling Details

Applicant Name:  M/s. Data Processing Forms P. Ltd.

Date:  22/01/2025

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