Classification of service— The present application has been filed by M/s. Maharashtra Ex-Servicemen Corporation Ltd., the applicant, seeking an advance ruling in respect of the following questions.-

Whether the Chapter No. 99, Sr. No. 3 of the Exemption Notification No. 12/2017 is applicable to MESCO Ltd. for the pure services i.e. Security Services rendered to various sites of Municipal Corporations in relation to functions entrusted to it under Article 243 W of the Constitution of India, thereby exempting as a service provider from the whole of GST?

The applicant is providing security services to various Government, Semi-Govt., Central PSUs, state PSUs offices including various Municipal Corporations e.g. Nagpur Municipal Corporation, Amravati Municipal Corporation, Aurangabad Municipal Corporation, Kolhapur Municipal Corporation, Latur Municipal Corporation, Parbhani Municipal Corporation, Solapur Municipal Corporation etc.

The only issue before us is whether the supply of security services by the applicant to the various Municipal Corporations are exempted from GST under the provisions of Exemption Notification No. 12/2017 – Central Tax (Rate) dated 28/06/2017 (Entry No. 3 of the Notification).

The applicant is of the opinion that the security services provided by it to all the Municipal Corporations are exempted from GST and has made submissions supporting its view. In support of its contention, the applicant has also cited the decision of this authority given in the case of Advance Ruling Application filed by M/s National Security Services.

Held that— The exemption under Sr. No. 3 of the Exemption Notification No. 12/2017 is available to the applicant for the pure services i.e. Security Services rendered to various sites of Municipal Corporations only if such pure services are supplied to the Municipal Corporations, in relation to functions entrusted to such Municipal Corporations under Article 243 W of the constitution of India.