2026-VIL-139-AAR

SGST Advance Ruling Authority

GST – Tamil Nadu AAR - Classification of Services - Composite Supply or not - Applicant engaged in upkeep and maintenance of Tamil Nadu Urban Habitat Development Board Housing Units under contract with Greater Chennai Corporation - Applicant claimed services constitute composite supply of goods and services entitled to nil rate of GST under Serial No. 3A of Notification No. 12/2017-Central Tax (Rate) – Applicable classification of upkeep and maintenance services and whether services qualify for composite supply exemption - HELD - Services of upkeep and maintenance of housing units encompassing sweeping, cleaning and garbage removal are appropriately classifiable under SAC 999423- General Waste collection services residential, which is specific and pertinent to nature of services undertaken rather than residuary heading. Services do not qualify for exemption under Serial No. 3A of Notification 12/2017-Central Tax (Rate) as requirement of composite supply is not satisfied - Composite supply requires supply made to recipient consisting of two or more taxable supplies of goods or services naturally bundled together in ordinary course of business with one principal supply. In present case no transfer of ownership or possession of any goods to Greater Chennai Corporation occurs. The consumables are merely specified for deployment and maintenance requirements and are only used for work performance, not supplied as goods to recipient. By applicant's own admission consumables and welfare kits have no transfer of ownership and are left as such after contract expiry. Condition in notification relating to value of goods not exceeding 25% of composite supply cannot be invoked when there is no composite supply at all - All conditions for exemption must be cumulatively satisfied. Since fundamental requirement of composite supply is not met, exemption eligibility cannot be sustained regardless of whether other conditions are satisfied - Services classified under SAC 999423 General Waste collection services residential. Applicant not eligible for exemption under Serial No. 3A of Notification 12/2017-Central Tax (Rate) as amended – Ordered accordingly

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