GST exemption for agricultural exhibition tickets applies only to activities linked to Panchayat functions; mixed entertainment access may be taxable.

Ticket charges for entry to an agricultural exhibition or carnival run by a university research station were treated as exempt from GST only where the services were provided by a Governmental Authority and were directly related to a Panchayat function under Article 243G, such as agriculture and agricultural extension. The exemption under entry 5 of Notification No. 12/2017-Central Tax (Rate) was confined to those qualifying activities. If admission also covered non-agricultural or entertainment activities, the ticket collection could lose the exemption and be taxable as a mixed supply.

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Issues: Whether ticket charges collected for admission to an agricultural exhibition/carnival conducted by a research station of the Kerala Agricultural University were exempt from GST under entry 5 of Notification No. 12/2017-Central Tax (Rate), and whether the exemption applied only when the activity was in relation to functions entrusted to a Panchayat under Article 243G of the Constitution.

Analysis: The applicant was treated as a Governmental Authority because the university and its research stations were constituted under a State enactment for agriculture-related research and extension, and agriculture including agricultural extension is a function entrusted to Panchayats under the Eleventh Schedule read with Article 243G of the Constitution. The exhibition activities described by the applicant, including crop displays, training, seminars, and demonstrations in farming methods, were held to be activities in relation to that Panchayat function. Entry 5 of Notification No. 12/2017-Central Tax (Rate) exempts services by a Governmental Authority by way of any activity in relation to any function entrusted to a Panchayat. The ruling also clarified that if the ticketed access extended to non-agricultural or entertainment activities, the exemption would not apply and the collection could become taxable as a mixed supply.

Conclusion: The ticket charges were eligible for GST exemption only to the extent they related exclusively to agricultural and extension activities covered by Article 243G; if the admission covered other non-covered activities, GST at 18% would apply.

Ratio Decidendi: Services provided by a Governmental Authority are exempt under entry 5 of Notification No. 12/2017-Central Tax (Rate) only when they are by way of an activity in relation to a function entrusted to a Panchayat under Article 243G of the Constitution; a ticketed bundle including unrelated entertainment or other non-qualifying activities loses that exemption and may constitute a mixed supply.

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