Governmental Authority exemption for municipal water supply services upheld; pure agent treatment rejected in a tripartite project arrangement.

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....DSCL qualified as a Governmental Authority because it was a government-established special purpose vehicle with 90% or more governmental equity/control and was set up to implement urban local body functions. Its services for the Smart City/ESCO water-supply project to UJS were exempt under Serial No. 4 of Notification No. 12/2017-Central Tax (Rate) because water supply is a Twelfth Schedule municipal function. The question whether the tripartite arrangement created two distinct supplies was held not maintainable within the questions raised. DSCL was also held not to be a pure agent under Rule 33, so the contractor-related amounts formed part of the value of supply.....