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AAR held that transfer of assets and liabilities from the transferor to the transferee constitutes a 'service by way of transfer of a going concern as a whole or an independent part thereof' and is therefore an exempt supply under Sl. No. 2 of N/N 12/2017-CT(R). It further ruled that the work orders relating to digital asset management, GIS/WebGIS-based monitoring and stakeholder orientation for the State PHE Directorate are 'pure services' to a Government department in relation to functions under JJM, eligible for exemption under Sl. No. 3 of N/N 12/2017-CT(R). Post-transfer invoices in continuation of such work orders retain the same taxability.
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