The AAAR determined that the appellant's services do not qualify...

The AAAR determined that the appellant's services do not qualify for tax exemption under Notification No. 12/2017. The key issue centered on service supply conditions, specifically direct service provision to government entities. While the appellant provided manpower services to Webel Technology Limited for a government project, the services were not directly supplied to the government. WTL, as the intermediary, was responsible for payment, thereby disqualifying the services from exemption. Consequently, the appellant failed to meet the requisite conditions for tax exemption, rendering the service supply taxable under the prescribed notification.

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