Classification of service— The present appeal has been filed against the Advance Ruling order.

The appellant has agreed to provide Project Management Consultancy Services to RUDSICO for Rajasthan Secondary Towns Development Sector Project in Joint Venture with Haskoning DHV Consulting Pvt. Ltd. And Haskoning DHV Nederland B.V. 

Appellant has filed an application before the Rajasthan Authority of Advance Ruling to determine the eligibility of the Project Management Consultancy services provided to Rajasthan Urban Drinking Water Sewerage and Infrastructure Corporation for Rajasthan Secondary Towns Development Sector Project can be termed as 'Pure Services' as referred in Entry No. 3 Notification No 12/2017 - Central Tax (Rate) Dated 28/06/2017.

Advance ruling authority hold that applicant is not eligible for aforesaid exemption. Appellant observed that they are entitled to the notification No. 12/2017 Central Tax rate.

Held that— This authority found that holding of equity control of RUDSICO by Jaipur Development Authority and Rajasthan Housing Board cannot be treated as holding of equity control by government. Accordingly, we hold that RUDSICO is not a Governmental Authority. Therefore, appellant is not eligible for exemption under notification no. 12/2017-Central tax (Rate) dated 28.06.2017.