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Applicant, a government company established by Central and State governments with 50% equity participation each, sought advance ruling on eligibility for exemption under Sr. No. 41 of Notification No. 12/2017-Central Tax (Rate) for leasing services provided. The Authority ruled that since the Central/State government has 20% or more ownership in the applicant entity, it is ineligible for the exemption. Hence, 18% GST is applicable on the leasing services provided.
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