Municipal Services Deemed Labour, Not Core Constitutional Functions, Disqualifying Tax Exemption Under Notification 12/2017

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....The AAR determined that the applicant's services to municipal councils, including property survey, numbering, measurement, and data digitalization, constitute pure labour services not directly related to constitutional functions under Articles 243G or 243W. While facilitating property tax assessment is essential for municipal operations, these specific services do not fall within the mandated municipal functions enumerated in the Twelfth Schedule. Consequently, the applicant is not eligible for the tax exemption under Notification No. 12/2017-CT (Rate), and standard tax provisions will apply to the services provided.....