2026-VIL-07-AAAR
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SGST AAAR

GST – Odisha AAAR - Government Authority/Entity – Appellant is a Government company with the objective of procurement of quality medicines, surgical and medical equipment, managing central drug warehouses, monitoring drug distribution counters, and procurement and maintenance of medical equipment across health facilities – Whether the appellant qualifies as a "Government Authority" or "Government Entity" under the GST law and the services provided by it are pure services eligible for exemption under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 – HELD – The appellant was incorporated under the Companies Act with 100% equity and control of the Government of Odisha to carry out the specific functions entrusted to it by the State Government, such as procurement of medicines and medical equipment, management of drug warehouses, and monitoring of drug distribution centers, which are intrinsically linked to the public health functions entrusted to Panchayats and Municipalities under the Constitution - the appellant-Corporation is a Government Entity in terms of the explanation in Para 2(zfa) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 - The services provided by appellant are "pure services" as it does not engage in any commercial or profit-making activities, and the service charges received by it are solely for meeting its recurring administrative and operational costs. The services provided by appellant are eligible for exemption under Sl. No. 3 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as the services are in relation to the functions entrusted to Panchayats and Municipalities under the Constitution - The appeal is allowed
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