2026-VIL-54-AAR
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SGST Advance Ruling Authority

GST – West Bengal AAR - Eligibility to exemption to Security services provided by security agencies to Food Corporation of India - Whether the security services qualify as 'pure services' provided to a Government Entity in relation to functions entrusted under Article 243G/243W of the Constitution of India and are exempt from GST under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as amended – HELD - The security services provided to FCI are pure services as they do not involve any supply of goods. FCI satisfies the criteria of a 'Government Entity' under the GST law, being established by an Act of Parliament and under the full ownership and control of the Central Government. The primary function of FCI is procurement, storage, movement, transport, distribution and sale of foodgrains and other foodstuffs throughout the country for the Public Distribution System (PDS), which is covered under serial no. 28 of the Eleventh Schedule to Article 243G of the Constitution – The security services are essential for safeguarding the foodgrains and foodstuffs stored for the purpose of PDS in the depots of FCI. Therefore, the security services provided to FCI are an activity in relation to the functions entrusted under Article 243G. However, the exemption under serial no. 3 of Notification No. 12/2017-Central Tax (Rate) is available only to the Central Government, State Government, Union Territory or local authority, and not to a Government Entity. Consequently, the security services provided to FCI, being a Government Entity, are not exempt from GST - The security services provided by the security agencies to FCI, qualify as 'pure services' provided to a Government Entity in relation to functions entrusted under Article 243G of the Constitution of India, but are not exempt from GST – Ordered accordingly
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