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Assignment of the right to collect royalty by a State to a contractor is treated as a taxable licensing service, but Entry 65B in Notification No.12/2017 (as amended) exempts services to Excess Royalty Collection Contractors (ERCC) subject to reconciliation and end of contract certification; consequence: ERCCs obtain conditional exemption on the assigned right fees. Separately, statutory levies (royalty, seigniorage, DMF, MERIT) remain taxable under the Reverse Charge Mechanism and are payable by the quarry/mining leaseholders; consequence: ERCCs collect and remit these amounts but do not bear GST on them, although ERCCs must pay GST on collection/agency services they provide to the Government.
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