https://www.taxtmi.com/highlights?id=105019 GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions. en-us Thu, 15 Oct 2026 05:44:05 +0530 Thu, 15 Oct 2026 05:44:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105019 GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions. Highlights GST Thu, 15 Oct 2026 05:44:05 +0530 https://www.taxtmi.com/highlights?id=105019