States GST & VAT - QUESTION : The applicant was engaged in the business as a collector of household data through mobile app for Function Household Tap Connection (hereinafter referred to as “FHTC Connection”) relating to water distribution networks for Directorate of Public Health Engineering across West Bengal. It sought advance ruling on the following questions: 1. Whether the potential services of collecting household data through mobile app for Function Household Tap Connection (FHTC Connection) provided in relation to water distribution networks be classifiable under sl. no. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 (as amended)? 2. In case where the answer to question No 1 is in negative, what shall be the classification and the rate of tax? RULING : 1. The work executed by the applicant do not represent any kind of works contract or composite supplies having any supply of goods involved in them. As such, the services provided can be regarded as Pure Service and qualifies for exemption under serial no. 3 of Notification No. 12/2017-Central Tax (Rate) Dated 28-6-2017, as amended. 2. Not answerable, in the light of Answer 1. M/s. Chhanda Bhattacharya, In re (2026) 127 ITPJ (SG) 330 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the business as a provider of field level data validation of Functional Household Tap Connection (FHTC) executed by various agencies on the basis of pictorial data with the objective of controlling multiple entry, improving data quality in terms of absolute household by verification through electric connection or any other unique documents and making error free database in different Piped Water Supply scheme for Directorate of Public Health Engineering (PHED) across West Bengal. It sought advance ruling on the following questions: 1. Whether field level data validation of Functional Household Tap Connection (in short FHTC) executed by various agencies on the basis of pictorial data with the objective of controlling multiple entry; improving data quality in terms of absolute household by verification through electric connection or any other unique documents; and making error free database in different Pipe Water Supply scheme and Organizing Orientation Programme for Implementation Support Agencies (in short ISAs) of District Project Management Unit (in short DPMU) and Engineer Officers on Functionality Assessment (Jal Mitra application web & mobile) along with evaluation of performance under Support Activities of Jal Jeevan Mission in the Districts of Howrah and Hooghly in relation to water distribution networks are classifiable under sl. no. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 (as amended)? 2. Whether services of collecting of different components of Piped Water Supply scheme and land information of head work site area and visualizing the key features with functionality assessment in relation to water distribution networks be classifiable under sl. no. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 (as amended)? 3. In case where the answer to question No 1 is in negative, what shall be the classification and the rate of tax? 4. In case where the answer to question No 2 is in negative, what shall be the classification and the rate of tax? RULING : 1. The work executed by the applicant do not represent any kind of works contract or composite supplies having any supply of goods involved in them. As such, the services provided can be regarded as Pure Service and qualifies for exemption under serial no. 3 of Notification No. 12/2017-Central Tax (Rate) Dated 28-6-2017, as amended. 2. All the activities are in relation to supply of drinking water in various parts of West Bengal. They are also related to the supply of safe and quality drinking water. All these activities are parts of the Jal Jeevan Mission (JJM) Scheme launched by the Central Government. Hence, they are classifiable under sl. No. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017. 3. Not answerable, in light of Answer No. 1. 4. Not answerable, in light of Answer No. 2. M/s. Amit Kumar Mukherjee, In re (2026) 127 ITPJ (SG) 329 (AAR) States GST & VAT - QUESTION : The Applicant is engaged in the business of Trading Tapioca Flour purchased from the registered dealers and effects sale within and outside the state of Tamilnadu. It sought advance ruling on the following questions: 1. Classification of goods, i.e., Tapioca Flour obtained by crushing the dried root, and remnants of tapioca roots/tubers. 2. Applicability of Notification issued under the provisions of Act in respect of goods falling under entry No. 78 and tariff item 1106 of Part-A of exempted goods, and tariff item 1106 in Sl. No. 59 of Part-C of schedule I of the said Act. 3. Determination of the liability to pay tax in respect of the said goods, tariff No. 1106 as mentioned in Sl. No. 78 of Part-A of exempted goods, and Sl. No. 59 of Part-C of I schedule to the Act. 4. Whether such trader/dealer is required to be registered. Authority for Advance Ruling held that the product is classifiable under HSN 230310 as ‘Residues of starch manufacture and similar residues’ liable to tax @5%; that the notification referred by the applicant is not applicable to them and the applicant is liable to be registered subject to the conditions prescribed under section 22 of the Act. Aggrieved by the decision, the appellant preferred an appeal before the Appellate Authority for Advance Ruling. RULING : 1. The product of the applicant namely, ‘Tapioca Flour’ is rightly classifiable under Chapter sub-heading 2303 1000. 2. As the said product is classified under 2303 1000, the exemption provided under Notification No. 02/2017-CT(Rate), dated 28-06-2017 is not applicable to the applicant. 3. Same as Answer 2. 4. The applicant, being a trader/dealer of ‘Tapioca Flour’ is required to be registered subject to the conditions prescribed under section 22 of the GST Act. V.S. Trading Company (Perumal Vasudevan), In re (2026) 127 ITPJ (SG) 326 (AAR) States GST & VAT - QUESTION : The applicant provides security services and scavenging services on contractual basis to various WB State Govt Medical Colleges & Hospitals, District Hospitals, Sub Divisional & other hospitals in West Bengal. It sought advance ruling on the question as to whether the services provided by the applicant to various Medical Colleges and hospitals of Government of West Bengal is exempted from GST under Notification No. 12/2017–Central Tax (Rate) dated 28-6-2017? RULING : Both security services in the form of providing security personnel and scavenging services in the form of providing scavenging staff to the government hospitals are undoubtedly activities in relation to both ‘Health and sanitation, including hospitals, primary health centres and dispensaries’ (vide entry no. 23) and ‘Public health, sanitation conservancy and solid waste management’ (vide entry no. 6). All the three conditions mentioned in Entry No. 3 of the Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 have been fulfilled in the case of the applicant’s activities as mentioned in the application and are therefore, exempted under the said notification. M/s. Ex Servicemen Resettlement Society, In re (2026) 127 ITPJ (SG) 331 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the activity of systematic collection, handling, storage, bundling, transportation, and final disposal of non-recyclable plastic waste generated in various Panchayats and Municipalities across Kerala. It sought advance ruling on the following questions: 1. Whether the solid waste management services rendered by Tiffot Private Limited to Clean Kerala Company Limited, including the collection, storage, transportation, processing, and bundling of non-recyclable plastic waste for co-processing, are exempt from GST under Entry 3B of Notification No. 13/2023-Central Tax (Rate), dated 19-10-2023, considering that the recipient is a Governmental Authority ?? 2. Further, in case such services are not explicitly covered under the aforementioned notification, whether they may qualify for GST exemption under any other notifications or circulars issued under the CGST Act, 2017, specifically where services provided to governmental authorities for public sanitation or environmental protection are covered? RULING : 1. The afore mentioned services rendered by Tiffot Private Limited to Clean Kerala Company Limited (CKCL) are exempt from GST under Entry 3B of Notification No. 13/2023-Central Tax (Rate), dated 19-10-2023. 2. As the services are squarely covered under Entry 3B of Notification No. 13/2023-Central Tax (Rate), dated 19-10-2023, question No. 2 is void ab initio. Tiffot (P.) Ltd., In re (2026) 127 ITPJ (SG) 324 (AAR) States GST & VAT - QUESTION : The applicant is a company headquartered in Kolkata with pan India presence and is a real estate company. It sought advance ruling on the following questions: 1. Whether the Sale of Specific Unit of Construction Site (All Assets & Liability pertaining to that Project will be transferred) at Surat as discussed in the Application, will be classified as “Slump Sale”? 2. Whether the Supply made as “Going Concern” by way of “Slump Sale” will be classified under SAC 997119? 3. If the answer to Question No. 2 mentioned above is yes, then whether the Applicant is eligible for Exemption under Notification No. 12/2017-CT (Rate) Dt. 28-6-2024 under the Entry No. (2)? RULING : 1. Since, there is no concept or definition of slump sale provided in the GST Act, the question was not answerable as to whether the sale in question would be classified as ‘slump sale’. 2. Supply made as “Going Concern” will be classified under SAC 997119. 3. Applicant is eligible for exemption under Notification No. 12/2017-CT (Rate) Dt. 28-6-2024 under the Entry No. (2). The ruling is subject to the condition that the agreement/contract of sale between the applicant and M/s. Samprati Buildcon Pvt. Ltd. is legally sustainable in the court of law. RDB Realty & Infrastructure Ltd., In re (2026) 127 ITPJ (SG) 323 (AAR) States GST & VAT - Section 73—Determination of tax—Show cause notice not served—Opportunity to file appeal ABC Enterprises v. STO & Ors. (2026) 127 ITPJ (SG) 322 (Del-HC) : 2025 TaxPub(GST) 994 (Del-HC) States GST & VAT - QUESTION : The applicant is engaged in the business of processing and exporting of shrimp. The applicant procures raw shrimp locally from farmers and processes it at the factory. Shrimp processing includes washing, de-veining, peeling, de-heading, tail removal, sorting, grading, and freezing. It sought advance ruling on the following questions: 1. Is the export of processed frozen shrimps (HSN 0306), which are packaged in individual printed pouches or boxes and subsequently placed inside a print master carton (with a maximum weight of 25 Kilogram each) that includes the design, label, and other specification about the product to GST? 2. Is the export of processed frozen shrimps (HSN 0306), packaged in individual printed pouches or boxes and subsequently placed inside a printed master carton weighing up to 25 kilograms, subject to GST? RULING : 1. According to the Notification No.6 of 2022-CTR dated 13-7-2022 “, GST is applicable on the export of ‘pre-packaged and labelled’ commodities as per the provisions of the Legal Metrology Act with effect from 18-7-2022. 2. As per the Notification No. 06/2022 (CT Rate), dated 13-7-2022, GST has been made applicable on supply of such “pre-packaged and labelled” commodities attracting provisions of Legal Metrology Act, 2009.Therefore, where the quantity involved is 25Kgs or less in respect of specified commodities including shrimps (HSN 0306, as per S.No.4 of schedule 1 of Notification No. 01/2017-Central Tax (rate), dated 28-6-2017) which are pre-packed, they would mandatorily get covered within the ambit of Legal Metrology Act, 2009, and the rules made there under. Therefore, GST would be applicable on the supply of “pre-packaged and labelled” shrimps, capacity upto 25 kgs, it will be liable for GST @ 5%, irrespective of the fact whether it is for domestic supply or for exported outside the country. Devi Fisheries Ltd., In re (2026) 127 ITPJ (SG) 320 (AAR) States GST & VAT - QUESTION : The applicant is engaged in B2B trading of goods wherein it provides transportation services of goods exclusively by road to the customers purchasing such goods from various E-Commerce Operator (“ECO”) portals. It sought advance ruling on the following questions: 1. Whether the services provided by the Applicant to customers would qualify as “Goods Transport Agency” (GTA) services? 2. Whether the services provided by the Applicant to unregistered customers through the electronic commerce operator’s portal would be eligible for exemption in terms of SL No. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 (as amended)? RULING : 1. If the transportation of goods is done entirely by road and the person transporting the goods issues consignment note, the time sensitive transportation of goods is to be considered as services by GTA. Therefore, the applicant is a GTA as per the proposed model and the services provided by the applicant is regarded as services provided by a GTA. 2. If the end customer to whom service is provided by the applicant in the capacity of a GTA is an unregistered person the services will be covered by entry no. 21A ibid. It is needless to mention that the incidental/ ancillary services provided strictly in relation to and in the course of the specific transportation of goods will also be covered by the exemption entry, by virtue of Circular No. 234/28/2024-GST dated 11.10.2024 issued by CBIC. M/s. Flipkart India Private Limited, In re (2026) 127 ITPJ (SG) 332 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the business of providing Digitalisation and Monitoring of Mega Schemes; Enhancer of the Jalmitra application; Digitization of the Piped Water Supply schemes; Collection, Scanning and Digitization of printed distribution drawings along with development of a GIS tool; Relevant Data management, analysis and documentation and other technical consultancy services relating to water distribution networks for Directorate of Public Health Engineering across West Bengal. It sought advance ruling on the following questions: 1. Whether based on facts of the instant case, transfer of assets and liabilities forming part of the business from M/s. Horizen amounts to “service by way of transfer of a going concern, as a whole or an independent part thereof” and is thus an exempt supply as classified under sl. no. 2 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 (as amended)? 2. In case where the answer to question No 1 is in negative, what shall be the classification and the rate of tax? 3. Upon the conveyance of the business to the applicant, a determination is required as to whether all supplies and/or invoices issued in furtherance of, or as an extension of, original work orders commenced under the name of the transferor, shall be deemed to possess the identical taxability as if such transactions had remained with M/s. Horizen or new tax treatment would apply due to the business transfer? RULING : 1. The work orders per se do not represent any kind of works contract or composite supplies having any supply of goods involved in them. The services can be regarded as pure services. As such, these services can be regarded as Pure Service and qualifies for exemption under serial no. 3 of Notification No. 12/2017-Central Tax (Rate) Dated 28-6-2017, as amended. 2. In view of the Answer 1, the question is not answerable. 3. Answer to this question should be given in two parts. For the work items mentioned in Paragraph 4.9 the ruling pronounced by this authority is not binding either on the applicant or on the jurisdictional officer. For the work items mentioned in Paragraph 4.10, it is ruled that they qualify for exemption under serial no. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017, as amended if the work orders remain the same as per the sample work orders placed before us. M/s. Horizen Edge Technologies Private Limited, In re (2026) 127 ITPJ (SG) 333 (AAR)