TaxTMI 
TaxTMI 
2026 (4) TMI 355
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.... an application for Advance Ruling under Section 97 of CGST Act, 2017 read with Rule 104 of CGST Rules, 2017 and Section 97 of KGST Act, 2017 read with Rule 104 of KGST Rules, 2017. 2. The Applicant is engaged in the supply of pure labour services to various single residential dwelling units. The Applicant does not provide such services to residential apartments or residential complexes. The services are supplied exclusively to stand-alone residential dwelling units. Further, the Applicant does not supply any material whatsoever, and the scope of work is strictly restricted to the supply of pure labour services only. 3. The Applicant has sought advance ruling in respect of the following question: "taxability on supply of pure....
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....unit otherwise than as a part of a residential complex is exempted from GST. 7. PERSONAL HEARING PROCEEDINGS HELD ON 18.12.2025: CA Aravind Kumar Diggi and Kedarnath M, tax consultant, the duly authorised representatives of the applicant, appeared for the personal hearing held on 18.12.2025 before this Authority and reiterated the facts as narrated in the application and stated that as per Entry No. 11 of Notification No. 12/2017-CT(R) dated 28.06.2017, as amended, services by way pf pure labour contracts of construction, erection, commissioning, or installation of original works pertaining to a single residential unit otherwise than as a part of a residential complex is exempted from GST. FINDINGS & DISCUSSION: 8. At the outset....
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....CT(R) dated 28.06.2017, as amended. The said Notification and definitions is reproduced below to decide the issue in question. 12.1 Entry Serial No. 11 of Notification No. 12/2017-CT(R) dated 28.06.2017 as amended:- Serial No. Chapter, Section, Heading, Group or Service Code (Tariff) Description of Services Rate (Per Cent) Conditions 11 Heading 9954 Service by way of pure labour contracts of construction, erection, commissioning, or installation of original works pertaining to a single residential unit otherwise than as a part of a residential complex. NIL NIL 12.2 The phrase "service by way of pure labour contracts of construction, erection, commissioning, or installation of original works pertaining to ....
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....sidential Complex" means any complex comprising of a building or buildings, having more than one single residential unit. 12.7 As per Paragraph 2 (zze) of Notification No. 12/2017-CT(R) "Single residential unit "means a self-contained residential unit which is designed for use, wholly or principally, for residential purposes for one family. 12.8 In view of the above, on a conjoint reading of Entry No. 11 of Notification No. 12/2017-Central Tax (Rate) along with the relevant definitions, it is evident that services by way of pure labour contracts, i.e., contracts where there is no transfer of property in goods and no material is supplied by the service provider, involving construction, erection, commissioning, or installation of origin....
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....ng projects, or residential complexes comprising multiple dwelling units with common infrastructure and shared facilities. From the facts placed on record, it is evident that the Applicant provides services only to individual owners of stand-alone residential houses and not to residential apartments or complexes. The services are rendered independently to single residential units and are not linked to any residential complex or project. 13. In view of the above facts and the legal position, we find that the services supplied by the Applicant satisfy all the essential conditions prescribed under Entry No. 11 of Notification No. 12/2017-Central Tax (Rate). Accordingly, the supply of pure labour services for construction, erection, commi....