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Security services consisting solely of deployment of guards are classified as pure services because they involve no supply of goods or works contracts; accordingly the supply to FCI qualifies as a service-only activity. However, the exemption in Sl. No. 3 of Notification No. 12/2017-Central Tax (Rate) requires the recipient to be the Central Government, a State Government, a Union territory or a local authority; a 'Government Entity' established by statute (FCI) does not fall within those specified recipient categories. Therefore the entry's exemption does not apply to security services supplied to FCI.
Security services consisting solely of deployment of guards are classified as pure services because they involve no supply of goods or works contracts; accordingly the supply to FCI qualifies as a service-only activity. However, the exemption in Sl. No. 3 of Notification No. 12/2017-Central Tax (Rate) requires the recipient to be the Central Government, a State Government, a Union territory or a local authority; a 'Government Entity' established by statute (FCI) does not fall within those specified recipient categories. Therefore the entry's exemption does not apply to security services supplied to FCI.
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