GST exemption for vendor services denied where amended notification omitted governmental authority from exempt entries.

GST exemption on pure services received from vendors was denied because the applicant was treated as a governmental authority established by an Act of Parliament, not as the Central Government. The authority noted that services such as manpower supply, housekeeping, security and accountancy were covered by the claim, but serial numbers 3 and 3A of Notification No. 12/2017, as amended from 01.01.2022, omitted "Governmental Authority" from the exempt service descriptions. As a result, the applicant could not rely on those entries to claim exemption, and the issue was answered in the negative.

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Issues: Whether the applicant was entitled to GST exemption on pure services received from vendors.

Analysis: The applicant sought exemption on services such as manpower supply, housekeeping, security, and accountancy services received from vendors, contending that its supplies were exempt and that it functioned as a Central Government institution. The ruling authority found that the applicant was not Central Government but a governmental authority established by an Act of Parliament. It further noted that serial numbers 3 and 3A of Notification No. 12/2017, as amended with effect from 01.01.2022, had omitted the phrase "Governmental Authority" from the description of exempt services, and therefore the applicant could not claim exemption under those entries.

Conclusion: The applicant was not entitled to GST exemption on the pure services received from vendors and the question was answered in the negative.

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