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    <description>Security services for guarding depots and offices were treated as pure services because no goods supply or works contract element was involved, but the GST exemption under entry 3 of Notification No. 12/2017-Central Tax (Rate) was unavailable because the recipient was a Government Entity and not the Central Government, State Government, Union territory or local authority. Although the services were linked to public distribution functions under Article 243G, that connection did not expand the exemption to a Government Entity. The services were therefore not exempt under the notification framework.</description>
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