Authority for Advance Ruling (AAR)

i)Whether administering of COVID-19 vaccination by hospitals is Supply of Good or Supply of Service?
ii) Whether administering of COVID-19 Vaccine by clinical establishments (Hospitals) qualify as “Health care services” as per Notification No. 12/2017 Central Tax Rate dated 28.06.2017?
iii) Whether administering of COVID-19 vaccination by clinical establishment is exempt under GST Act?

Whether the “Supply of Manpower for preparation and serving of spot Electricity Bills’ services provided to Andhra Pradesh Central Power Distribution Corporation Limited for Andhra Pradesh Rural Electrification including distribution of electricity (APCPDCL) can be termed as ‘Pure Services’ as referred in Sl.No.3- (Chapter 99) of table mentioned in Notification No.12/2017- Central Tax (Rate) dated 28.06.2017 and accordingly eligible for exemption from Central Goods and Service Tax and Sl.No.3 (Chapter 99) of table mentioned in G.O.Ms.No.588 – (Andhra Pradesh) State Tax (Rate) Dated 12/12/2017 and accordingly eligible for exemption from Andhra Pradesh Goods and Service Tax

1. Whether the supply of labour services for collection of seeds from forest, digging contour trenches, chal-khal (water conservation pits in hills) for soil and moisture conservation, clearing of fire lines in forest to protect forest from fire which causes damage to forest, controlled burning of portion of forest to prevent spread of fire and damage to environment in included in exempted services in Notification No. 12/2017 Central Tax (Rate ) dated 28-06-2017 or any other related exemption notification.

2. If above supply of service is not included in any exemption notifications as per Question 1, the rate of goods and service tax applicable to such supply of services.

3. Whether the supply of services for raising seedlings in nursery is exempted services in Notification No. 12/2017 Central Tax (Rate) dated 28-06-2017 or any other related exemption notification.

4. If above supply of service is not included in any exemption notifications as per Question 3, the rate of goods and service tax applicable to such supply of services.

5. Whether the supply of services for plantation in forest is exempted services in Notification No. 12/2017 Central Tax (Rate) dated 28-06-2017 or any other related exemption notification.

6. If above supply of service is not included in any exemption notifications as per Question 5, the rate of goods and service tax applicable to such supply of services.

7. Whether the supply of services for creation of check-dam for Soil and Moisture Conservation is exempted services in Notification No. 12/2017 Central Tax (Rate) dated 28-06-2017 or any other related exemption notification.

8. If above supply of service is not included in any exemption notifications as per Question 7, the rate of goods and service tax applicable to such supply of services.

9. The section 51 of the CGST specifies that TDS is to be deducted when total value of taxable goods or services or both under a contract exceeds Rs 2,50,000. Most the mentioned works in this application are small in nature. Therefore, the value of single contract in most cases is less than Rs 2,50,000. However, the service provider registered with the department provides services for many works like one contract for nursery, second for plantation, third for fire lines and so on. The value of all contract combined may become more than Rs 10 Lakhs in some cases. Whether, TDS is to be deducted if applicant gives contract for multiple works to the contractor, the cumulative contract value is more than Rs 2,50,000. However, work order of single contract is less than Rs 2,50,000

Whether brass puja utensils like diya, samai, agarbatti stand, pach arti, dhuparti, nandadeep, hawankund and other utensils used in puja daily in households are covered by Tariff Heading 7418 or Tariff Heading 7419.

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?

1.  Whether the transfer of land, held under lease by FDCM, towards Kolsapada Minor  Irrigation Project is supply of service?

2. Whether exemption under Entry No 3. Of Notification No. 12/2017 Central Tax (Rate), dated 28.06.2017 will be applicable on the amount of compensation received by FDCM against transfer of land held under lease for Kolsapada Minor Irrigation Project?

1.Whether, the Applicant is acting as a pure agent of the Industry partner to the extent of reimbursement received towards stipend paid to Trainees on behalf of Industry partner as part of training agreement and therefore the said reimbursement is not chargeable to GST?

2.Whether, the Applicant is acting as a pure agent of the Industry partner to the extent of reimbursement received against cost of employee compensation insurance obtained for the benefit of Trainees by the Applicant and reimbursed by the Industry partner as per the training agreement and therefore the said reimbursement is not chargeable to GST?

A.Whether from the facts and circumstances of the case, supplies made by the applicant to the Examination Boards and Educational Institution are entitled for exemption from payment of Good and Service Tax under Sr. No. 66, Heading No. 9992 (education Services) of the exemption Not. No. 12/2017-CT (Rate) dated 28-6-2017, read with Not. No. 14/2018-CT (Rate) dated 26-7-18. 
B.If yes, whether the applicant is entitled for refund of the taxes collected and paid into Govt. treasury so far.

Whether, Lamba Therapeutics Research Ltd. is eligible to avail ITC paid by World Courier?

1. Is Brindavana Gardens Park Entrance Fees exempt vide Notification No. 12/2017- Central Tax (Rate) dated: 28.06.2017 under the following entries?
- Entry No. 79 - Services by way of admission to a National Park (Heading 9996),
- Entry No. 81(b) - Services by way of right to admission to Musical Performance (Heading 9996)
- Entry No. 76 - Services by way of public conveniences such as provision of facilities of Bath Rooms, Wash Rooms, Lavatories, Urinal or Toilets (Heading 9994)

2. Is Toll Collection for use of Bridge is exemptedvide Notification No. 12/2017- Central Tax (Rate) under the following entries?
- Entry No. 23 - Services by way of access to a road or a bridge on payment of toll charges
- Entry No. 23(A) - Services by way of access to a road or bridge on payment basis.