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    <description>Pure services are exempt under Entry 3 of Notification No. 12/2017-Central Tax (Rate) only when supplied in relation to a function entrusted to a Panchayat or Municipality under Articles 243G or 243W; mere status as a Government Entity is not enough. The institute was treated as a Government Entity, but its higher-education activity was held not to fall within the relevant constitutional function list, and the manpower supply, security, horticulture, civil maintenance and electrical maintenance services had no nexus with any Panchayat or Municipality function. The exemption was therefore unavailable, and the services were held taxable under GST.</description>
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      <description>Pure services are exempt under Entry 3 of Notification No. 12/2017-Central Tax (Rate) only when supplied in relation to a function entrusted to a Panchayat or Municipality under Articles 243G or 243W; mere status as a Government Entity is not enough. The institute was treated as a Government Entity, but its higher-education activity was held not to fall within the relevant constitutional function list, and the manpower supply, security, horticulture, civil maintenance and electrical maintenance services had no nexus with any Panchayat or Municipality function. The exemption was therefore unavailable, and the services were held taxable under GST.</description>
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