Ruling on Tax Exemption for Planning Services to Gujarat's R&B Dept; Blanket Exemption Denied Without Specific Proof.

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....The case concerns the classification of services provided by the applicant to the R&B department of the Government of Gujarat. The issue was whether the services of preparing plans, estimates, and DTP for building works qualify as pure services and are exempt u/s 3 of N/N. 12/2017-CT (R). The Authority for advance ruling (AAR) held that the services provided were indeed pure services. However, the blanket exemption sought by the applicant for all buildings constructed for the State government was not granted. The applicant must prove that the buildings are related to functions entrusted to a Panchayat or Municipality to be eligible for the exemption. The services provided do not qualify as activities u/r Article 243G or 243W of the Constitution.....