For Full Access To All Latest Judgments on GST
Click Here To Subscribe Now
Take a tour of our GST Library

"Supply of Manpower for preparation and serving of spot Electricity Bills” services provided to Andhra Pradesh Central Power Distribution Corporation Limited for Andhra Pradesh Rural Electrification including distribution of electricity cannot be termed as 'Pure Services'

Classification of service— In the instant case, the applicant is engaged in 'supply of manpower' for preparation and serving of spot electricity Bills to Andhra Pradesh Central Power Distribution Corporation Limited (APCPDCL) with 18% GST (SAC -00440410) as per the terms of the contract.

The applicant seeks advance ruling on the following:

1. Whether the "Supply of Manpower for preparation and serving of spot Electricity Bills' services provided to Andhra Pradesh Central Power Distribution Corporation Limited for Andhra Pradesh Rural Electrification including distribution of electricity (APCPDCL) can be termed as 'Pure Services' as referred in SI.No.3-(Chapter 99) of table mentioned in Notification No. 12/2017- Central Tax (Rate) dated 28.06.2017 and accordingly eligible for exemption from Central Goods and Service Tax and SI.No.3 (Chapter 99) of table mentioned in G.O.Ms.No.588 - (Andhra Pradesh) State Tax (Rate) Dated 12/12/2017 and accordingly eligible for exemption from Andhra Pradesh Goods and Service Tax.

In the instant case, the Scope of the supply as mentioned by the applicant includes supply of both goods and services.

Thus the transaction covers the procurement of goods as well in addition to the services, disqualifying the present supply to be covered under the concept of 'pure services'.

Hence the exemption clause under entry SI.No.3- (Chapter 99) of table mentioned in Notification No.12/2017- Central Tax (Rate) dated 28.06.2017 is not applicable for the instant case. In view of the above, the rest of the issues like APCPDCL being a 'Local Authority' or the supply being one of the functions entrusted to panchayat under Article 243G of the Constitution, find no relevance to take up for further discussion.

Held that— "Supply of Manpower for preparation and serving of spot Electricity Bills' services provided to Andhra Pradesh Central Power Distribution Corporation Limited for Andhra Pradesh Rural Electrification including distribution of electricity (APCPDCL) cannot be termed as 'Pure Services' as referred in SI.No.3-(Chapter 99) of table mentioned in Notification No.12/2017 Central Tax (Rate) dated 28.06.2017.

"Supply of Manpower for preparation and serving of spot Electricity Bills” services provided to Andhra Pradesh Central Power Distribution Corporation Limited for Andhra Pradesh Rural Electrification including distribution of electricity cannot be termed as 'Pure Services'

The applicant seeks advance ruling on the following:

In the instant case, the Scope of the supply as mentioned by the applicant includes supply of both goods and services.

Thus the transaction covers the procurement of goods as well in addition to the services, disqualifying the present supply to be covered under the concept of 'pure services'.