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AAR held that the applicant's supply of 'Fresh Waste Processing' machinery to Anand Municipal Corporation constitutes a supply of goods only, falling under Chapter 84 (HSN 8479, 8428, 8462, 8474) of the GST Tariff. As there is no provision of 'pure services' nor a composite supply where goods do not exceed 25% of the value, the exemption under Sl. No. 3 or 3A of Notification No. 12/2017-CT(R) is inapplicable. Consequently, the transaction is taxable as a supply of goods to a local authority, chargeable to GST at 18% on the machinery supplied.
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