Classification of service— In the instant case, the appeal has been filed against the Order passed by the Tamil Nadu State Authority for Advance ruling.

The applicant is a “Municipality” as defined in clause (e) of article 243P of the Constitution. They are rendering taxable services (viz) renting of immovable property service, mandap keeper service. They are doing the functions entrusted to a municipality under Twelfth Schedule to Article 243W of the Constitution. They are rendering the following functions directly as well as through con tractors(through tender process) and collecting Fee from parks, Market fee daily, Market fee-weekly, Fee for entry vehicle in the market, Fees for pay and use toilets, slaughter house fees, Fees for bays in bus stand (bus stand entrance fee collection), lius stand (others), charges for TV advt. in bus stand. locker rent proi Hen bus-stand, cycle stand, scooter, auto, four wheeler stand in bus stand and oilier places, Hunk stalls, annual track rent — cable operator fee (Optical fibre laying fee).

Held that— In respect of Q. No. 1, SI. No. 5-B (Rent for locker provided in bus stand by the appellant) it is held to be an activity undertaken by the Municipality as a function entrusted under 243W of the Constitution and the service of rent or fee collection for such a facility is neither a Supply of Goods nor a supply of Service as per Notification No. 14/2017-CT (Rate)

In respect of Q. No. 2, the transaction between the corporation and the contractor as listed in SI. No. 1 to 9, except Sl. No. 51A Charges for TV advt. in Bus Stand & SI. No. 6-Bunk Stall’ of the said question, in the factual matrix presented, it is held to be an activity/transaction in relation to activity/transaction undertaken by the appellant engaged as Public authority and the same are covered under Notification No. 11/2017 C.T.(Rate) as amended

In respect of Q. No. 2, Sl. No. 5A..Chargcs for TV advt. in Bus Stand SI. No. 6 Bunk Stall’ of the said question, the same is covered under SI. No. Notification No. 12/2017 CT (Rate) as well as charging of tax on RCM basis under Sl. No. 5 of Notfn No. 13/2017-CT (Rate)subject to fulfillment of the conditions therein is available to appellant.

In respect of supply of services of allowing road cutting and the subsequent track renting, the situation being factual in as much as the road cutting is followed by laying of cables by the telephone companies front whom tract rent is collected, the supply would be a ‘Composite Supply’, restricted to this particular activity and riot extended to all types of road cutting activities.