Specified-recipient condition for GST exemption defeats sub-contracted manpower claims where services are supplied to private contractors.
Case-Laws
GST
GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions.
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