Pure labour services linked to municipal functions qualify for GST exemption under the relevant notification.

Pure labour services with no supply of goods were treated as exempt under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) because they were supplied in relation to municipal functions under Article 243W. The activities of creating fire lines, plantation of trees, river maintenance and clearing forest truck paths were regarded as connected with Twelfth Schedule functions, including fire services, urban forestry and protection of the environment, so the exemption applied.

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Issues: Whether pure labour services for setting up fire lines in forests, plantation of trees, river maintenance and clearing of truck paths in forests are exempt under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017 as services in relation to functions entrusted under Article 243W of the Constitution of India.

Analysis: The services rendered were found to be pure services, as no supply of goods was involved. Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) exempts pure services supplied to Government or a Governmental entity when the activity is in relation to functions entrusted to a Municipality under Article 243W of the Constitution of India. The relevant Twelfth Schedule functions include fire services, urban forestry and protection of the environment, and the activities of creating fire lines, plantation, river maintenance and clearing of forest paths were treated as falling within that scope.

Conclusion: The services are exempt under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017.

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