Pure-service exemption for municipal sanitation manpower requires an identifiable qualifying municipal-function supply, leaving non-exempt outsourcing taxable at applicable rates.
Case-Laws
GST
Pure-service exemption for municipal sanitation manpower depends not merely on designations such as Sweeper or Paryavaran Mitra, but on contractual scope, actual deployment, supporting records, supply to the specified recipient, and a connection with qualifying municipal functions. Recipient views, contractual GST clauses, and past tax practice do not determine taxability. The manpower outsourcing arrangement lacked contractual and factual segregation of a separately identifiable qualifying supply and was therefore not exempt. Non-exempt outsourcing is taxable under the applicable service classification; the intra-State supply attracted 18% GST, subject to classification and rate-notification verification.
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