2025 (3) TMI 1293

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....fficer or the appellant within a period of six months from the date of the order. Provided that, no rectification which has the effect of enhancing the tax liability or reducing the amount of admissible input tax credit shall be made, unless the appellant or the appellant has been given an opportunity of being heard. 2. Under Section 103 (1) of the Act, this advance ruling pronounced by the Appellate Authority under Chapter XVII of the Act shall be binding only. (a) On the appellant who had sought it in respect of any matter referred to in sub-Section (2) of Section 97 for advance ruling; (b) On the concerned officer or the jurisdictional officer in respect of the appellant. 3. Under Section 103 (2) of the Act, this ....

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....nding provision under the TGST Act. Further, for the purposes of this Advance Ruling, the expression 'GST Act' would be a common reference to both CGST Act and TGST Act. 3. This appeal is filed against the Order No.12/2021 dated 04.10.2021 ("impugned order") passed by the Telangana State Authority for Advance Ruling (Goods and Services Tax) ("Advance Ruling Authority"/"AAR"/"lower Authority"). Brief facts of the case: 4.1 M/s Telangana State Technology Services Limited (TSTSL) Telangana State Public Sector Undertaking and TSTSL is a Service Agency to the Telangana Government and its Departments relating to Information Technology and its related services. 4.2 One of Such services provided by TSTSL is, acting as a fund manager on ....

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....reads as follows: "Services by the Central Government, State Government, Union territory or local authority excluding the following services: (a) Services by the Department of Posts by way of speed post, express parcel post, life insurance, and agency services provided to a person other than the Central Government, State Government, Union territory; (b) Services in relation to an aircraft or a vessel, inside or outside the precincts of a port or an airport; (c) Transport of goods or passengers; or (d) Any service, other than services covered under entries (a) to (c) above, provided to business entities." 5.3. A careful reading of the said Entry in the Notification reveals that this entry perta....