Pure service exemption depends on proof of service-only supply; missing contract prevented GST exemption verification.

Exemption under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) applies only where the supply is a pure service, without goods, works contract, or composite supply elements, and is provided to a specified government recipient for functions connected with Articles 243G or 243W. In this matter, the applicant claimed exemption for consultancy services supplied to a urban development authority, but did not produce the governing agreement. On the documents available, the AAR could not verify whether the supply was confined to services alone or whether it included goods or works contract elements, so it could not determine GST exemption eligibility.

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Issues: Whether the applicant's consultancy services supplied to Rajkot Urban Development Authority qualified as pure services eligible for exemption under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Analysis: The exemption under Serial No. 3 applies only to pure services that do not involve supply of goods and are not works contract or composite supplies, when provided to specified government recipients for activities connected with functions under Articles 243G or 243W of the Constitution. The applicant relied on the status of the recipient authority and the nature of the project, but did not produce the agreement governing the work. On the material available, the authority could not verify whether the supply was confined to services alone or whether it involved goods or works contract elements, particularly in relation to the affordable housing project.

Conclusion: The exemption could not be ruled upon on the available documents, and it was not possible to decide whether the services were pure services or whether GST exemption was available.

Ratio Decidendi: Exemption under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) requires proof that the supply is a pure service, and the claim cannot succeed without the relevant contractual documents establishing the nature of the supply.

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