Government School Services Exempt, Colleges Taxable under GST Notification

The ruling confirmed that security, cleaning, and housekeeping services provided to specific government schools are exempt from GST under Notification No.12/2017-CT (R). However, services provided to government colleges, hospitals, and offices mentioned in the case are taxable and not eligible for exemption under the same notification.

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Issues Involved:
1. GST applicability on manpower services provided to Central Government, State Government, Local Authorities, Governmental Authorities, and Government Entities.
2. Exemption eligibility under Notification No.12/2017-Central Tax (Rate) dated 28-6-2017 for pure services provided to various governmental bodies.

Issue-wise Detailed Analysis:

1. GST Applicability on Services to Government Schools:
The applicant provides services such as security, cleaning, and housekeeping to government schools. As per Sr.No.66(b) of Notification No.12/2017-CT (R) dated 28-6-17, services provided to educational institutions up to higher secondary school level are exempt from GST. The relevant services include security, cleaning, and housekeeping. The ruling confirms that services provided to:
- Girls Literacy Residential School, Karchond, Dharampur, Valsad (housekeeping and cleaning).
- Government Secondary Schools of Chhotaudepur district (housekeeping, cleaning, and security).
- Model School, Naswadi, Chhotaudepur (security).
are exempt from GST under the said notification.

2. GST Applicability on Services to Government Colleges:
The scope of exemption under Sr.No.66(b) of Notification No.12/2017-CT (R) excludes colleges providing education above higher secondary schooling. Therefore, services provided to government colleges are taxable. The following institutions fall under this category:
- Shri C.H.Bhil Government Arts & Commerce College, Naswadi, Chhotaudepur.
- Government Arts College, Kanvat, Chhoteudepur.
- Govt. Science College-Pardi, Valsad.
- District Education and Training Institute, Valsad.
- Government Basic Woman Pedagogic School, Vadodara.

3. GST Applicability on Services to Government Hospitals:
Exemption for services provided by clinics/clinical establishments is covered under Sr.No.46 and 74 of Notification No.12/2017-CT (R). However, these exemptions do not cover services provided to such establishments. The contracts pertaining to hospitals include:
- Veterinary Hospital, Valsad.
- Veterinary Hospital, Dharampur.
- General Hospital, Chhotaudepur.
The ruling confirms that services provided to these hospitals are not exempt from GST.

4. GST Applicability on Services to Government Offices:
The applicant contends that services provided to government offices should be exempt under Sr.No.3 of Notification No.12/2017-CT (R). However, the ruling clarifies that there is no specific exemption for services provided to government offices. The services provided to government offices cannot be equated to services in relation to Panchayat/Municipality functions. The ruling dismisses the applicant's claim for exemption under this notification for services provided to government offices.

Ruling:
1. Security, cleaning, and housekeeping services provided to the cited schools are exempt from GST.
2. GST is applicable on services provided to all cited government colleges providing education above higher secondary level.
3. GST is applicable on services provided to all cited government offices.
4. GST is applicable on services provided to all cited government hospitals.

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