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Pure Services classification applies to security guards, but recipient-based exemption excludes service supplied to a Government Entity.

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Full Text of the Document

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....Security services consisting solely of deployment of guards are classified as pure services because they involve no supply of goods or works contracts; accordingly the supply to FCI qualifies as a service-only activity. However, the exemption in Sl. No. 3 of Notification No. 12/2017-Central Tax (Rate) requires the recipient to be the Central Government, a State Government, a Union territory or a local authority; a 'Government Entity' established by statute (FCI) does not fall within those specified recipient categories. Therefore the entry's exemption does not apply to security services supplied to FCI.....