TaxTMI 
TaxTMI 
2021 (6) TMI 520
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..... Erode. 638 001. (Hereinafter called the 'Applicant) is registered with GSTIN No. 33AAALT1781BIZB. The applicant is a "Municipality" as defined in clause (e) of article 243P of the Constitution. They are rendering taxable services (viz) renting of immovable property service, mandap keeper service and are doing the functions entrusted to a municipality under Twelfth Schedule to Article 243W of the Constitution. They have stated to undertake the following services directly/ through contractors by tender process and have sought ruling on the application of Notifications specified in Column E below: Sl.No. Description of the service Direct service by the corporation Service through contractors by tender process Advance ruling is required on the following whether the services mentioned in Column B are exempted vide Notfn No. or Sl. No. entry of the table to Notfn as noted against each Sl.No. in Column E. A B C D E 1. Fee from parks Some times in some months Three years lease Notfn. No. 14/2017 dt 28-06-2017 (or) sl no 4 of 12/2017 dt 28-06-2017 2. Market fee-daily Some times in some months Three years lease Notfn. No. 14/2017 ....
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....se No. 162/2018, dated 28-5-2018. (iii) SI no 24 of the table to Notification No. 11/2017-C.T. (Rate), dated 28-6-2017. 11. Right to fishing in bond Three years lease (i) Sl. No 5 of Notfn. No 12/2017-C.T. (Rate), dated 28-6-2017. (ii) Sl.no. 24 of the table to Notification No. 11/2017-C.T. (Rate), dated 28-6-2017 12. Running a fish market Three years lease Sl no 5 of Notfn. No 12/2017 or Sl no 24 of 11/2017 dated 28-06-2017. 13. For entry vehicle in the market For entry vehicle in the market Three years lease Notfn No 14/2017 dt 28-06-2017 (or) sl no 4 of Notfn. No 12/2017 dt 28-06-2017. 14 annual track rent -Cable operator laying fee (optical fibre laying fee) Based on contract Composite supply can be applied for road cutting charges by treating it as renting of immovable property service and reverse charge is applicable under Sl No 5A of Notfn No. 13/2017 dated 28-06-2017 as amended 15 Renting of immovable property Direct by the municipality on lease contract Nonpayment of tax under reverse charge under SI No 5A of Notfn No 13/2017 dated 28-06-2017 but paid under direct c....
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....exempted or not as per SI no 8 of the table to Notfn. No 12/2017 dated 28-06-2017. The Applicant has submitted the copy of application in Form GST ARA - 01 and also submitted a copy of Challan evidencing payment of application fees of Rs. 5,000/- each under sub-rule (1) of Rule 104 of CGST rules 2017 and SGST Rules 2017. 2.1 The applicant has stated that they are rendering the following functions directly as well as through contractors (through tender process)and collecting Fee from parks, Market fee-daily, Market fee-weekly, Fees for bays in bus stand (bus stand entrance fee collection ), Bus-stand (others), charges for TV advt. in bus stand, locker rent provided in bus-stand , flower shop in bus stand in open space, cycle stand, scooter, auto, four wheeler stand in bus stand and other places and collection of room rent for temporary stay, Slaughter house fees, Bunk stalls, Rent - traveler's bungalows & rest house (municipal lodge), Fees on pay &use toilets, Avenue receipts, Right to fishing in Pond, Running a fish market, fee for entry vehicle in the market, annual track rent -Cable operator laying fee(optical fiber laying fee). 2.2 They have stated that, they undertake ....
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....RC buildings; Cycle stand, scooter, auto and four-wheeler stand in bus stand; collection of room rent for temporary stay • collection of Slaughter house fees collection of Bunk stalls • Rent -travelers' bungalows & rest house -municipal lodge • collection of Fees on pay & use toilets • Avenue receipts.- enjoyments of fruits of the trees in high ways of particular area • Right to fishing in Pond- Enjoyments of right - fishing in a particular Pond • Running a Fish market. -right to sell fish in a particular shop in a specified area • Collection of fees for entry of vehicle in the Market and in such cases: • service provider is the applicant. • Service is allowing the tender contractor who succeeded in the tender process and who is the service recipient: • the right to collect the fees as per the prescribed conditions of tender in respect of fees for the various amenities fixed by the applicant; • the right to use the advertisement through TV in the bus stand; • the right to collect the rent of locker in the bus stand; temporary st....
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....ir interpretation of law, has referred to • the definitions of "agent" under Section 2(5); "Consideration" under Section 2(31); "Supplier" under Section 2(105); "Taxable Supply" under Section 2(108) of the GST Act. • Schedule I of the CGST Act 2017 relating to Supply of Goods by a Principal to his agent/ by an agent to the Principal • Section 7 (2) of CGST Act 2017 • Notification No. 14/2017-C.T.(Rate) dated 28^th June 2017 • The functions entrusted to a municipality under the Twelfth Schedule to Article 243 W of the Constitution • Section 270-B, 374, 358, 359 of the Tamil Nadu District Municipalities Act 1920 3.2 They have stated that in general, their activities under consideration are purely on public interest and are undertaken as mandatory and statutory functions. It could not to be treated as a service as per the Notfn. No. 14/2017. Therefore, such activities assigned to and performed by a sovereign / public authority under the provisions of any law, could not be treated as taxable service. Any amount / fee collected for such activity could not to be treated as consideration for the purpose of le....
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.... of urban amenities and facilities such as parks, gardens, playgrounds. o cycle stand, scooter, auto, four wheeler stand in bus stand is covered under (q) of Twelfth Schedule to Article 243W of the Constitution which reads as follows : q) Public amenities including street lighting, parking lots, bus stops and public conveniences o Collection of room rent for temporary stay in Bus Stand is covered under (l) and (q) of the Twelfth Schedule to Article 243 W of the Constitution which reads as follows: (l) Provision Of urban amenities and facilities such as parks, gardens, playgrounds. (q) Public amenities including street lighting, parking lots, bus stops and public conveniences It is also exempted as per entry SI No 14 of the Notfn No. 12/2017 also since the amount collected by the municipality is less than Rs. 1,000/-and hence exempted. • Slaughter house fees: - Maintenance of slaughter house are covered under (r) of the Twelfth Schedule to Article 243 W of the Constitution which reads as follows: (r) Regulation of slaughter houses and tanneries Further exempted vide SI.No. 56 of Notfn. No. 12/2017-C.T.(Rate)....
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....nstitution could not be termed as service. As there is no service the question of payment of GST will not arise on all those lease contracts since the rate fixed by Govt. was adopted and the service was rendered by the contractor to the public in the name of the local authority and receipt has been issued in the name of the local authority to the public. 3.5 Apart from the general contention, as above in respect of the activities undertaken entirely through contractors, the applicant has stated as follows: • Bus Stand - TV Advt in bus Stand: As per entry Sl.No. 7 of Notfn. No. 12/2017-C.T. (Rate) dated 28.06.2017, the services provided by the applicant to the business entity whose aggregate turnover is less than exemption limits in the preceeding financial year the GST chargeable is 'NIL' subject to the conditions specified therein and even if an argument is placed that it is chargeable to tax, it is chargeable under reverse charge as per Sl.No. 5 of Notification No. 13/2017-C.T.(Rate) dated 28.06.2017 • Bus Stand- Flower shop in the bus stand 4X4 in open space in various places in the bus stand - is covered under (i) of Twelfth Schedule to Article 243W....
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.... renting of immovable property service. As per SI no 5A of the table to Notification No. 13/2017- Central Tax (Rate) New Delhi, the 28th June, 2017 the telephone companies who are registered with GSTN have to pay GST under reverse charge. 3.7 Renting of Immovable Property - Even after 25-01-2018 they continued to collect GST under direct charge from the person registered with GSTN and the same was paid to Govt. The services rendered by them has suffered tax. It is a technical lapse that the service availer (GSTN registered holder) has not discharged their liability as per the Notfn.No. 13/2017-C.T.(Rate) dated 28.06.2017. They stated that they felt that tax need not be paid once again under reverse charge. 3.8 Renting of immovable property service to another central /state Govt Departments - As per Sl No 8 of the table to Notfn Not 2/2017 central tax (rate) dated 28-06-2017 as amended the renting Of immovable property service rendered by them as a local authority to pure state Govt. offices (viz) Asst. Director Of L F Accounts,: Project Officer, ICDS, ICDS Centre: Deputy Supt. Of Police and pure Central Govt offices (viz) post offices are fully exempted. The renting of immova....
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....covered as under: Sl.No. Description of the service Entry of Twelfth Schedule under which the service is covered A B C 1 Fee from parks (1) of 243W 2 Market fee-daily (xxii) of 243G 3 Market fee -weekly (xxii) of 243 G 4 Fees for bays in bus stand (bus stand entrance fee collection) (q) of 243 W 5 Bus -stand (others) (A) charges for of TV advt. in bus-stand (B) locker rent provided in bus-stand (C) flower shop in bus stand in open space (D) cycle stand, scooter, auto, four wheeler stand in bus stand and other places (E) collection of room rent for temporary stay NA (l) of 243 W (i) & (xxii) of 243 G and (i) of 243 W (q) of 243 W (q) of 243 W 6 Slaughter house fees (r) of 243 W 7 Bunk stalls (xvi) & (xxviii) of 243 G 8 Rent -travellers bungalows& rest house (municipal lodge) (q) of 243 W 9 Fees on pay & use toilets (q) of 243 W 10 Avenue receipts (i) of 243G 11 Right to fishing in bond (v) of 243 G 12 Running a fish market (v) of 243 G & (xxii) of 243 G 13 For entry vehicle in the market (l) of 943 W and (xxii) of....
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....ct. They stated that the observation of the Commissioner in the SCN had greater impact on the questions raised in the proceedings in hand and requested that the same may be taken into consideration while deciding the application. They furnished the following documents • SCN No. 06/2018-Commr dated 24.10.2018 issued by the Commissioner of GST & Central Excise • Form SVLDRS-I, its acknowledgement, Form SVLDRS-3, Form-SVLDRS 4(Discharge Certificate) • Circular No. 89/7/2006-ST dated 8th December 2006 • Sample contract orders in respect of Fee from parks, Market fee-Daily, Market fee-Weekly, fee from bays in bus-stand, Fee on Pay & use toilet • Sample token issued by the contractor in the name of Municipality for parking in cycle, two-wheeler in bus-stand • Sample token issued by the contractor in the name of Municipality for Pay & use toilet in the bus-stand • Copy of contract for cable operator laying fee • Rental receipts issued to • General Manager, PNB • Integrated Child Welfare Dev. Office • Senior Post Master, Erode • Divisio....
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....ubmitted that there is no pending proceedings in the applicant's case in their jurisdiction on the issue raised by the applicant in the Application. They further submitted the following comments on which advance ruling is sought as to whether the said services are taxable or otherwise as follows: • Fee from Parks -if maintained directly are exempted • Market fee- daily & Weekly - not covered under Article 243 W; activity appears to be renting of immovable property services and are taxable subject to exemption under Sl.No. 9 of the Notification No. 12/2017-C.T.(Rate) dated 28.06.2017; When the said service is provided through contractors through tender process the same is also taxable • Fees for bays in bus-stand- Bus stand entrance fee collection- covered under entry (q) of the functions entrusted to Municipalities under Article 243 W and Sl.No. 4 of Notfn No.12/2017-C.T.(Rate) is applicable to the same • Bus stand others- a.TV Advt., (c) Flower Shop, (e) Collection of room rent for temporary stay are commercial in nature. Hence, tax has to be paid on these items; (b) Regarding Locker Rent it is not covered under the functions ent....
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....and, (B) locker rent provided in bus-stand, (C) flower shop in bus stand in open space, (D) cycle stand, scooter, auto, four wheeler stand in bus stand and other places and (E) collection of room rent for temporary stay; (6) Slaughter house fees; (7) Bunk stalls; (8) Rent -traveler's bungalows & rest house (municipal lodge); (9) Fees on pay & use toilets; (10) Avenue receipts; (11) Right to fishing in Pond; (12) Running a fish market; (13) fee for entry vehicle in the market; (14) annual track rent -Cable operator laying fee(optical fiber laying fee); (15) & (16) Renting of immovable property to State/ Central Government offices, Co-op societies, banks, etc. They have stated that they require clarifications whether these activities are covered under Twelfth Schedule of Article 243 W of the constitution so as to claim appropriate exemption under Notfn No. 14/2017-C.T.(Rate) dated 28.06.2017 as amended and sl.No. 4 of Notification no. 12/2017-C.T.(Rate) dated 28.06.2017 as amended apart from their eligibility to exemption vide various entries of the exemption ....
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.... Section 97 (2) of the CGST Act / Tamil Nadu GST Act (TNGST) gives the scope of Advance Ruling Authority, i.e., the question on which the Advance Ruling can be sought. For ease of reference, the section is reproduced as under: 97 (2) The question on which the advance ruling is sought under this Act, shall be in respect of,- (a) classification of any goods or services or both; (b) applicability of a notification issued under the provisions of this Act; (c) determination of time and value of supply of goods or services or both; (d) admissibility of input tax credit of tax paid or deemed to have been paid; (e) determination of the liability to pay tax on any goods or services or both; (f) whether applicant is required to be registered; (g) whether any particular thing done by the applicant with respect to any goods or services or both amounts to or results in a supply of goods or services or both, within the meaning of that term. The Act limits the Advance Ruling Authority to decide the issues earmarked for it under Section 97(2) and no other issue can be decided by the Advance Ruling Authority. The question at....
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....tfn 14/2017 dt 28-06-2017(or) sl no 4 of 12/2017 dt 28-06-2017 E. Notfn 14/2017 dt 28-06-2017(or) sl.no. 04 of 12/2017 dt 28-06-2017 or Sl no 14 of 12/2017 dated 28-06-2017 6 Slaughter house fees (r) of 243 W Notfn No. 14/2017 dt 28-06-2017(or) sl no 4 of 12/2017 dt 28-06-2017 8 Rent -travellers bungalows & rest house (municipal lodge) (q) of 243 W Notfn No 14/2017 dt 28-06-2017 or sl no 4 of Notfn. No 12/2017 dt 28-06-2017 & Sl.no. 14 of the same Notfn/-since condition is satisfied. 9 Fees on pay & use toilets (q) of 243 W Notfn No 14/2017 dt 28-06-2017 (or) sl no 76 of Notfn. No 12/2017 dt 28-06-2017. 13 For entry vehicle in the market (l) of 943 W and (xxii) of 243 G Notfn No 14/2017 dt 28-06-2017 (or) sl no 4 of Notfn. No 12/2017 dt 28-06-2017. 7.2 From the table above, it is seen that the applicant claims that the activities are those in relation to that listed at (i), (l), (q), (r) of the Twelfth Schedule of the Constitution under Article 243 W/(i) and (xxii) of the Eleventh Schedule of the Constitution under Article 243 G. The said entries of the Eleventh and the Twelfth Schedule of the Constitution are as under: ....
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....fined in clause (d) of article 243 of the Constitution; (b) a "Municipality" as defined in clause (e) of article 243P of the Constitution; .................................; (g) a Regional Council constituted under article 371A of the Constitution Applying the above, to the case at hand, the applicant being a Municipality as defined in clause (e) of article 243 P of the Constitution, is a Local Authority under the GST Act. Therefore, if the services listed at Sl. No. 1 to 6, 8, 9 & 13 are found to be that in relation to the entries of Eleventh [Twelfth Schedule of the Constitution, and the said activities are undertaken by the applicant, a Local authority, when engaged as a 'Public Authority', then the said activities are to be treated neither as supply of goods nor supply of services effective from 26.07.2018. 7.4 Alternatively, the applicant has claimed that the services are covered under the exemption at Sl.No. 4 of Notification No. 12/2017-C.T.(Rate) dated 28.06.2017 as amended. The entry Sl.No. 4 is as below: 4 99 Services by local authority or governmental authority by way of any activity in relation to any function entrusted to a mun....
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....function-Provision of Urban amenities and facilities such as Parks' as per entry (l) of the Twelfth Schedule of the constitution. The said activity when provided by the applicant, as per Notification No. 14/2017 C.T.(Rate) dated 28.06.2017 as amended with effective from 26.07.2018, is neither a supply of goods nor supply of service and not taxable to GST. 2. & 3. Market Fees- Daily & Weekly- It is stated that the applicant collects entrance fee from the farmers/ Merchants on daily basis for allowing them entry into the market. From the submissions, it is seen that the considerations are for the infrastructure of the shop (thatched shop/ thatched shed/ RC shop/ AC Sheet shed) in the market, open space allotted and the entities (vegetable bundle/ fish basket/ hen/ handcart/ coconut/ leaves bundle/ tomato basket) brought to the market. Providing 'Markets & Fairs' is a function listed at (xxii) of Eleventh Schedule under Article 243 G and the applicant being a local authority is to provide such Markets for the convenience of the Public. The considerations collected based on the infrastructure extended to the farmers/ merchants and the entities brought for sale are to convenien....
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.... public to park cycle/scooter/auto/car on hourly/daily basis in the bus-stand. The consideration is charged towards maintenance of such facility. They claim that the activity is in relation to the function at (q) of the Twelfth Schedule of the Constitution. 'Public amenities including street lighting, parking lots, bus stops and public conveniences' is listed at (q) of the said Schedule. The applicant provides parking lots which is an activity specified in the said entry. The applicant undertakes the above activity as a public authority and therefore, the said activity when provided by the applicant, is neither a supply of goods nor supply of service as per Notification No. 14/2017C.T.(Rate) dated 28.06.2017 as amended effective from 26.07.2018. E. Collection of Room Rent for temporary stay: The applicant has stated that the activity is allowing public to use single bed room / double bed room on daily basis in the bus-stand. They have claimed that the activity is a function listed at (q) of the Twelfth Schedule of the constitution. As, it can be seen, the said entry provides 'Public amenities including street lighting, parking lots, bus stops and public conveniences.' Rent....
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....sis. They have claimed that the activity is a function listed at (q) of the Twelfth Schedule of the constitution. As, it can be seen, the said entry provides 'Public amenities including street lighting, parking lots, bus stops and public conveniences'. Renting room for temporary stay on daily rent basis is not an activity in relation to the activities stipulated in the entry (q), as it is not in the genre of the inclusive-activities specified in the said entry. Therefore, providing rooms for temporary stay in the Bus-stand is not an activity in relation to the function at (q) of the Twelfth Schedule and hence, Notification No. 14/2017-C.T.(Rate) dated 28.06.2017 as amended is not applicable to this activity. Alternatively, the applicant has claimed the eligibility to exemption as stipulated under Sl.No. 14 of the Notification No. 12/2017-C.T.(Rate) dated 28.06.2017, which is examined as under. For ease of reference, the said entry' is reproduced below: 14 Heading 9963 Services by a hotel, inn, guest house, club or campsite, by whatever name called, for residential or lodging purposes, having value of supply of a unit of accommodation below or equal to one thousand rupees p....
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....ctivity in relation to function '(xxii) Markets & Fairs' entrusted to a Panchayat under Article 243 G of the Constitution. The applicant undertakes the above activity as a public authority and therefore, the said activity when provided by the applicant, is neither a supply of goods nor supply of service as per Notification No. 14/2017-C.T.(Rate) dated 28.06.2017. 7.6 In view of the above, we hold that the activity (1) Fee from Parks; (2) Market fee-daily; (3) Market fee-weekly; (4) Fees for bays in bus-stand; 5(D)- Cycle stand, Scooter, auto, four wheeler stand in the bus-stand and other places; (6) Slaughter house fees; (9) Fees on pay & use toilets; (13) Fees for entry of vehicle in the Markets are activities in relation to functions entrusted under Article 243 G and Article 243 W Of the Constitution and are treated as neither supply of goods nor services when provided by the applicant as 'Public authority' as per Notification No. 14/2017-C.T.(Rate) dated 28.06.2017 as amended vide Notification No. 16/2018 dated 26.07.2018. In respect of activity 5(B) Locker Rent, 5(E) Renting room for temporary Stay in the bus-stand and (8) Renting Room in the Municipal Lodge, these activitie....
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....statutory provisions referred by the applicant are examined as under: Section 358 of the Tamilnadu District Municipalities Act, 1920 states as: 358. Application of term 'public servant' to municipal officers, agents and subagents .- Every municipal officer or servant, every contractor or agent for the collection of any municipal tax, fee or other sum due to the Municipal Council and every person employed by any such contractor or agent for the collection of such tax, fee or sum shall be deemed to be a public servant within the meaning of Section 21 of the Indian Penal Code (Central Act XLV of 1860). Section 21 of the Indian Penal Code is as below: 21. "Public Servent". The words "public servant" denote a person falling under any of the descriptions hereinafter following; namely:- ................................................ [(Twelfth) -Every person- (a) in the service.......................... Government; (b) in the service or pay of a local authority, a corporation established by or under a Central, Provincial or State Act or a Government company as defined in section 617 of the Companies Act, 1956 (1 of 1956). ....
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....ncluding a factor, broker, commission agent, arhatia, del credere agent, an auctioneer or any other mercantile agent, by whatever name called, who carries on the business of supply or receipt of goods or services or both on behalf of another; Thus, a person who carries on the business of supply of service on behalf of another is defined as 'agent'. Section 2 (105) Of the GST Act, defines supplier as: (105) "supplier" in relation to any goods or services or both, shall mean the person supplying the said goods or services or both and shall include an agent acting as such on behalf of such supplier in relation to the goods or services or both supplied; In the case at hand, the criteria for the contractors to be termed as 'agent' of the applicant is when the contractors act on behalf of the applicant, i.e., when such contractors are assigned only the collection of the fees fixed by them and remittance of the same to the applicant. On perusal of the various conditions of the tender Documents and the contracts, it is seen that the contract is awarded to the successful bidder for a period of three years. The rates at which various fees are to be collected item-wise are fixe....
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....inciple-agent relationship is not acceptable and rejected. 8.5 In this scenario, the ruling sought on whether in respect of services rendered by them from SI.No. 1 to 13 through tender contractors are covered under Twelfth Schedule to Article 243W of the Constitution and/or exempted vide the Notfn. no. mentioned against each SI No is taken up for consideration. As brought out in para 8.4 above, the applicant supplies the 'Right to collect the fees/ Right to enjoy the fruits of leased avenue trees/ right to fish in the pond/ right to sell in the fishing market' in respect of the various activities form Sl.No. 1 to 13 in the table mentioned at Para 1 above. Supply of Rights held by the applicant to the contractors through the tenser process is a supply made by the applicant to the contractors, who are business entities for furtherance of their business and is not an activity in relation to the functions entrusted under Article 243 G/243W and therefore the considerations received from the successful contractors are liable to 8.6 On the question whether in respect of the services rendered by them from SI.No. 1 to 13 through tender contractors are covered under Twelfth schedule to....
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....cable and (ii) renting of road for the optical cables. Their claim is renting of space for laying cable is the principal supply and therefore applying the definition of 'composite Supply' under S.2(30) of the GST Act, road cutting charges has to be treated as renting and the whole service has to be classified as renting of immovable property. 9.3 On perusal of the document C2/6950/2020 dated 5.3.2020 issued to M/s. JIO digital, it is seen that permission is granted to erect pillars and Optical fiber cable in the Sky space along the road for the required length of the road. The same is permitted on payment of Track rent. On perusal of the document C2/7527/2015 dated 27.04.2017 issued to M/s. Idea Cellular Limited, it is seen that permission is granted to lay OFC cable alongside the walls of the storm water drain for a fixed length of road, on payment of Road Cutting Charges and annual track rent charges. It is further seen that the Track rent is accounted under Accounting head 1308007 and the Road cutting charges (Road restoration) is accounted under Accounting head 1407001. From the above, it is evident that while Annual Track rent is a recurring charge to be paid by the service....
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....ered by them as a local authority to State Govt. offices and Central Govt offices are fully exempted. The renting of immovable property service rendered by them as a local authority to Co-operative society are not exempted but chargeable to tax since the society and transport corporation TNSTC are covered under the definition of Government Entity only and they are not State Govt. Nationalised Banks are not central Govt. and so the services rendered to them are not exempted but chargeable to tax. 10.3 From the Lease Agreement executed on the 10th day of June 2020, it is seen that the applicant has leased a part of the premises owned by them to the Punjab National Bank for a monthly rent. Also, from the rental receipt copies furnished by the applicant in respect of Senior Post Master dated 03/sep/ 2020, it is seen that the premises is leased on monthly rental basis. The nature of supply is 'Renting of immovable property' as claimed by the applicant. The issue to be decided is whether the exemption under SI.No. 8 of the Notification NO. 12/2017C.T.(Rate) dated 28.06.2017 is applicable to such supplies. 10.4 The entry at Sl.No.8 of the Notification No. 12/2017-C.T.(Rate) is as fo....
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....8-06-2017 as amended vide Notfn. No. 16/2018 dated 26.07.2018 5 (B) Locker rent facilities (D) Providing stand for cycle, scooter, auto, four wheeler stand in bus stand and other places (E) Providing room for rent for temporary stay (B) Facility of providing locker for rent directly by the applicant is taxable for the reason that this does not fall under Notification No 14/2017 dt 28-06-2017 and is taxable (D) Not a Supply of Service as per Notification. No. 14/2017-CT(R) & dt 28-06-2017 as amended vide Notfn. No. 16/2018 dated 26.07.2018 (E) This is exempted from tax as per SI. No. 14 of Notification 12/2017-CT(R) dated 28.06.2017 for the reason that their room rent/day/person is not exceeding rupees 1000/-. 6 Providing Slaughter house facilities Not a Supply of Service as per Notification. No. 14/2017-CT(R) & dt 28-06-2017 as amended vide Notfn. No. 16/2018 dated 26.07.2018 8 Providing travellers bungalows & rest house This is exempted from tax as per SI. No. 14 of Notification 12/2017 CT(R)- dated 28.06.2017 for the reason that their room rent/day/person is not exceeded rupees 1000/-. 9 Providing Toilet facilities Not a Supply of S....