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    <title>Manpower Supply to WTL is Pure Service, No GST Exemption Under Notification 12/2017 Entry 3</title>
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    <description>The AAR held that the applicant&#039;s supply of personnel to WTL constitutes a pure service and not a composite supply or works contract. NKDA, constituted under the New Town Kolkata Development Authority Act, 2007, qualifies as a local authority; however, the service recipient is WTL, not NKDA, as payment flows from NKDA to WTL and then to the applicant on a back-to-back basis. Consequently, the applicant does not directly supply services to the local authority. Since all conditions of Entry No. 3 of Notification No. 12/2017-Central Tax (Rate) are not met, the exemption under the said notification is inapplicable. Therefore, the applicant is not entitled to the nil-rated GST exemption and must charge GST in its invoice to WTL for the manpower supply services rendered.</description>
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    <pubDate>Wed, 23 Jul 2025 08:29:43 +0530</pubDate>
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      <title>Manpower Supply to WTL is Pure Service, No GST Exemption Under Notification 12/2017 Entry 3</title>
      <link>https://www.taxtmi.com/highlights?id=90817</link>
      <description>The AAR held that the applicant&#039;s supply of personnel to WTL constitutes a pure service and not a composite supply or works contract. NKDA, constituted under the New Town Kolkata Development Authority Act, 2007, qualifies as a local authority; however, the service recipient is WTL, not NKDA, as payment flows from NKDA to WTL and then to the applicant on a back-to-back basis. Consequently, the applicant does not directly supply services to the local authority. Since all conditions of Entry No. 3 of Notification No. 12/2017-Central Tax (Rate) are not met, the exemption under the said notification is inapplicable. Therefore, the applicant is not entitled to the nil-rated GST exemption and must charge GST in its invoice to WTL for the manpower supply services rendered.</description>
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