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The services provided by the appellant towards APEPDCL does not qualify "the category of services provided to Government Authority meant pre­dominantly for use other than for commerce", as the services supplied by the appellant are purely commercial in nature even though the service recipient i.e., APEPDCL is a Government entity. Therefore the appellant is not eligible for concessional rate of tax 12%

Rate of tax (service)- The appellant is engaged in electrification work to the APEPDCL for procurement of plan, design, supply, install and commission certain facilities viz., providing underground cable work in Visakhapatnam city, package-1 and package-3 (replacement of existing 33/11 KV substation of Zone-i division Visakhapatnam with underground power cable network on turnkey basis. The Authority for Advance Ruling, A.P., had ruled that even though APEPDCL is covered under Government entity, the appellant is not entitled for the benefit of concessional rate of GST @ 12% as the works undertaken by APEPDCL are for business purpose. Hence we do not find any merit in the above contention and rejecting the same due to the lack of legal or statutory support to the argument. Held that- We uphold the decision of the Authority for Advance Ruling, A.P. confirming that the work contracts service rendered by M/s. Vijai Electricals (the appellant) to APEPDCL is not eligible for concessional rate of tax 12%
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