Pure services exemption applies to civic maintenance and sanitation services supplied to a Governmental Authority for municipal functions.

Pure services supplied without any transfer of goods to a Governmental Authority are covered by the exemption under Serial No. 3 of Notification No. 12/2017-State Tax (Rate) when the services relate to functions entrusted to a Municipality. Colony maintenance, solid waste management, water supply operation, garbage collection, cleaning, drainage and allied civic services were treated as municipal functions under Article 243W and the Twelfth Schedule. Because the recipient was constituted under State legislation and functioned under Government control, it was regarded as a Governmental Authority, and the exemption applied to the services supplied in relation to those public functions.

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Issues: Whether the colony maintenance, solid waste management, water supply operation, garbage collection, cleaning, drainage and allied services supplied to Chhattisgarh Housing Board were covered by the exemption for pure services under Serial No. 3 of Notification No. 12/2017-State Tax (Rate).

Analysis: The services were found to be pure services, with no transfer of property in goods involved. The recipient was treated as a Governmental Authority because it was constituted under State legislation and functioned under Government control. The nature of the services corresponded to municipal functions listed in Article 243W of the Constitution and the Twelfth Schedule, including water supply, sanitation, solid waste management, slum improvement, parks and related civic amenities. These conditions satisfied the entry granting exemption to pure services provided to Government, local authority or Governmental Authority in relation to functions entrusted to a Municipality.

Conclusion: The services supplied by the applicant were held to be exempt under Serial No. 3 of Notification No. 12/2017-State Tax (Rate).

Final Conclusion: The ruling recognizes the supply as a tax-exempt pure service when rendered to the specified public authority in relation to municipal functions, and denies the exemption where goods are involved or the recipient falls outside the specified class.

Ratio Decidendi: Pure services supplied without transfer of goods to a Governmental Authority, in relation to functions entrusted to a Municipality under Article 243W, fall within the exemption under Serial No. 3 of Notification No. 12/2017-State Tax (Rate).

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