States GST & VAT - QUESTION : The applicant is engaged in exporting of Men’s Pyjama Set consisting of a top (Kurta/Shirt) and bottom (pyjama/trouser) made of cotton, (TOP-67% Cotton, 29% Polyester, 4% Spandex Woven Shirt; Bottom -67% Cotton, 29% polyester, 4% Spandex woven pant) in 2 sets/pack. It sought advance ruling on the following questions: 1. Under which HSN Code should men’s pyjama sets with above mentioned description be classified? 2. What is the applicable GST rate on such men’s pyjama sets which are packed in 2 sets as per their buyer’s instruction and the cost of such packed pyjama sets are more than Rs. 1000. RULING : 1. Men’s Pyjama Sets consisting of woven Shirt and woven Pant made of cotton is to be classified under HSN code 620721. 2. GST rate of tax applicable for 2 Pyjama sets packed in a single pack and costing less than Rs. 1,000 per piece or set will be 5% (i.e. CGST-2.5% + SGST-2.5%) as per S.No. 223 of Schedule I of Notification No. 1/2017-Central Tax (Rate) dated 28-6-2017. Link up Textiles (P.) Ltd., In re (2026) 127 ITPJ (SG) 658 (AAR) States GST & VAT - QUESTION : The applicant is a company, wholly owned by Government of Kerala under the administrative department of Labour & Skills and is managed by Board of Directors comprising of Secretaries of various departments and industrial experts. It sought advance ruling on the following questions: 1. In view of the Notification No. 12/2017-Central Tax (Rate), dated 28-6-2017, we would like to get clarified whether the share of fee received from our skill training partners and fee collection from our own skill training institutes fall under taxable service or not? 2. If GST applicable for the income as per the provisions of the Act, can we avail Input Tax credit on the amount spent from the grant received from Government in relation to the generation of such income? RULING : 1. (a) The share of fee received by the applicant from its skill training partners does not qualify for exemption under Notification No. 12/2017-Central Tax (Rate). Accordingly, such receipts shall be liable to GST. (b) In the absence of documentary evidence to establish that the courses offered by the applicant’s own skill training institutes are in relation to any programme covered under the notification, the exemption is not applicable. Accordingly, the fee collected by the applicant from students -. enrolled in its own training institutes shall be liable to GST. 2. In the absence of specific details regarding the inputs and their use, no conclusive ruling can be given. However, it is clarified that the source of funds such as government grants does not, by itself, restrict ITC eligibility, provided the inputs are used for making taxable supplies and conditions under section 16 of the CGST Act are satisfied. Kerala Academy for Skills Excellence, In re (2026) 127 ITPJ (SG) 657 (AAR) States GST & VAT - QUESTION : The applicant through its division EVM Wheels, operates a self-drive “Rent a Cab” service across Kerala. It sought advance ruling on the following questions: 1. Whether the services rendered by the applicant fall under the chapter 99, heading 9973 and service code 997311? 2. Whether the rate provided in Notification No.11/2017 Central Tax (Rate), dated 28-6-2017 as amended vide Notification No.20/2019 CT (Rate) under the Sl. no. 17(viii) is applicable for the services rendered by the Applicant and the applicable GST rate of tax is 18%. RULING : 1. The services rendered by the applicant are classifiable under Chapter 99, Heading 9973, Service Code 997329 (“Leasing or rental services concerning other goods”), and not under SAC 997311. 2. Serial No. 17(viia) of Notification No. 11/2017-Central Tax (Rate), dated 28-6-2017, as amended, is. applicable to the applicant’s services, and the applicable GST rate is the same as the rate applicable to the supply of like goods. Serial No. 17(viii) is not applicable. EVM Passenger Cars India (P.) Ltd., In re (2026) 127 ITPJ (SG) 656 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the business of providing work contract services in addition to engineering consultancy services to various Government agencies like R & B Department, Capital Project Division, Project Implementation Unit etc. It sought advance ruling on the following questions: 1. Whether providing services of preparing and providing plans and estimate and preparing and providing DTP (Draft Tender Plan) for the building work provided by the assessee to the R&B department, Government of Gujarat under the contract would qualify as an activity in relation to Panchayat or Municipality under article 243G or article 243W respectively, of the Constitution of India ?; 2. If answer to the first question is in affirmative then, whether such service provided by the applicant would qualify as pure service (excluding works contract service or composite supplies involving supply of any goods) provided to the Central Government, State Government or Union Territory or local authority by way of any activity in relation to any function entrusted to a Panchayat under article 243G of the constitution or in relation to any function entrusted to a Municipality under article 243W of the Constitution as provided in serial number 3 of Notification No. 12/2017-CT(R), dtd 28-6-2017, and, thus be eligible for exemption from levy of CGST and SGST respectively? RULING : 1. Yes, but only in respect of services provided for the following buildings/structures: - (i) Industrial Training Institute (I.T.I) of Government (ii) Nalsarovar Bird Sanctuary (iii) Government School Building, Boys and Girls Hostel and District Library (iv) Female dormitory of New Beggars Receiving Centre (v) Storm Water Drain (vi) Centres under Intensive Cattle Development Program (ICDP), Intensive Poultry Development Project and Animal Husbandry EPI Centre. (vii) New Rehabilitation Home for women and persons cured after treatment from mental illness. (viii) Fish Farm (Pond Steps and Shed) and its Office (ix) Beej Nigam Seed Godown The services provided to those buildings other than the above would not qualify as an activity in relation to Panchayat or Municipality under article 243G or Article 243W respectively, of the Constitution of India. 2. Yes, but only in respect of the services provided for the buildings mentioned in Answer to Question No. 1. Devendra K Patel, In re (2026) 127 ITPJ (SG) 654 (AAR) States GST & VAT - QUESTION : The applicant required a power demand of 4500 KVA at a system voltage of 66KV for a high tension (HT) power connection at the manufacturing facility. It selected, M/s Rajesh Power Services Pvt. Ltd (the vendor), from the approved authorised vendors of GETCO, to execute the installation of the underground cable line and supply the requisite materials. It sought advance ruling on the question as to whether the applicant is eligible to avail ITC on procurement of capital goods & related services in the form of wires/cables, electric equipment, supervision charges & installation service used for transmission of electricity from power station of DISCOM to the factory premises which are installed outside the factory as per rules & policy of GETCO in accordance with the provision of sections 16 & 17 of the CGST Act, 2017? RULING : The applicant is eligible to avail ITC on procurement of capital goods & related services in the form of wires/cables, electric equipment, supervision charges & installation service used for transmission of electricity from the power station of DISCOM to the factory premises which are installed outside the factory. Alleima India (P.) Ltd., In re (2026) 127 ITPJ (SG) 653 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the structural engineering and construction sector, offering a suite of specialized services that include Post-Tensioning Solutions, Turnkey Structural Execution, Structural Design & Consultancy, Retrofitting & Strengthening and Quality Assurance & Technical Support. It sought advance ruling on the following questions: 1. What documents should be attached while sending material to sites apart from DC and way bill? 2. What type of documents must be attached while transporting machinery for doing service? 3. Some time we operate works for the sites from neighbouring states, for example we have our AP office at Vijayawada, to execute works at Ananthapur we send material from our Bangalore store as stock transfer and afterwards send machines from Bangalore to carry out the service part. We are facing challenges for material movement and machinery movement, seek direction to execute such works without hindrance from GST cross border officers. RULING : The questions raised by the applicant pertain to procedural/ documentation requirements relating to movement of goods and machinery, which are not covered under any of the clauses of section 97(2) of the CGST/APGST Act, 2017, the application is held to be not maintainable. Accordingly, the application is rejected in terms of section 98(2) of the CGST Act, 2017. Crux Prestressing Systems (P.) Ltd., In re (2026) 127 ITPJ (SG) 652 (AAR) States GST & VAT - QUESTION : The applicant is carrying on two business verticals, namely; first being trading of Cement and Iron and the second, transportation of goods by road. It sought advance ruling on the following questions: 1. What is the value of supply under section 15 of GST Act, 2017 in case of a supply of cement, iron or both to an unrelated person for which price is the sole consideration? 2. What is the value of supply under section 15 of GST Act, 2017 in case of a supply of cement, iron or both to M/s. Janaki Maha Lakshmi Steels, a related person who is eligible to claim input tax credit on the said supply? 3. Whether the registered person is liable to pay tax on the services of transportation of goods by the road to an unregistered person or not? If yes, at what rate of tax? 4. Whether serial no. 18 of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 or Serial no. 21A of Notification No. 32/2017-Central Tax (Rate) dated 13-10-2017 issued under section 11 of CGST Act, 2017 applicable to the registered person or not in case of services provided to unregistered persons? RULING : 1. Transaction value i.e., the price actually paid or payable. (Refer section 15(1) of GST Act, 2017) 2. Invoice value. (Refer Rule 28 of Central Goods and Services Tax Rules, 2017) 3. No, refer sl. no. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 as amended by Notification No. 32/2017-Central Tax (Rate) dated 13-10-2017 4. Refer sl. no. 21A of Notification No. 12/2017-Central Tax (Rate) dated 28-6-2017 as amended by Notification No. 32/2017-Central Tax (Rate) dated 13-10-2017. Janaki Maha Lakshmi Traders, In re (2026) 127 ITPJ (SG) 648 (AAR) GST - Input Tax Credit Reversal of ITC Upon Change of States of Goods from Taxable to Exempt—D. Ramachandra Rao GST - General provisions relating to determination of tax—Order passed without considering assessee’s request of third adjournments—No order passed on assessee’s request letter Pinky Marbles v. Director General of GST Intelligence (2026) 127 ITPJ (G) 623 (Raj-HC) GST - Revocation of cancellation of registration—Assessee willing to pay due tax and file GST returns—Allowability of BBK Corpn. v. UOI (2026) 127 ITPJ (G) 605 (Bom-HC)