Planning, estimates and DTP services for public building works not GST-exempt under Article 243G/243W absent direct municipal function link

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....The AAR held that the applicant's supply of planning, estimates and DTP services for building works to a state R&B department do not attract GST exemption under the entries linked to Article 243G/243W unless the services bear a direct and proximate relationship to a function entrusted to a Panchayat or Municipality. Exemption notifications are to be strictly construed and the onus lies on the taxpayer to demonstrate applicability. The Authority concluded the services provided for listed public buildings and facilities (including ITI, bird sanctuary, government schools and hostels, rehabilitation homes, animal husbandry centres, storm water drains, fish farm facilities and seed godown) do not qualify as activities "in relation to" Panchayat/Municipality functions.....