Levy of GST— In the instant case, the M/s NHPC was the implementing agency of the project entrusted with getting the project completed, by the Ministry of External Affairs. No specific aid or grant was made in the name of M/s NHPC; rather its expenses were to be repaid by MEA from their account head 'Aid to Nepal'. So the government aid was allotted to MEA and not to NHPC. 

The only point that has been contested by the appellant is on the apparent effect of the ruling of AAR based on the finding that since the M/s NHPC is providing Works Contract service which is exempted under notification. No. 12/2017-CT(R) dated 28.06.2017, so all the subsequent sub contracts will be also exempted. Here, we would like to make it clear that AAR ruling has a limited implication and is legally binding only on the applicant who has sought it and is specific to the questions raised by the applicant.

Held that— In the present case, M/s NHPC had raised a specific query as to whether they need to pay GST on reverse charge to PWD and to that extent, the ruling was that they are not required to do so. Whether the taxability on provision of works contract will be applicable on the works contract allotted by PWD is not an issue raised in the advance ruling application, Hence, we refrain from going into specifics of the same, thus, without going into the merits, we are of the view that since there was no taxability till the stage of PWD on account of entry 9c of notification 12/2017 as amended time to time