AAR: Data-Collection Work for Tap-Connection Mapping Treated as Pure Services; GST Fully Exempt

Chhanda Bhattacharya, a GST-registered professional from North 24 Parganas, sought an advance ruling from the West Bengal AAR on the GST implications of a proposed assignment from the Public Health Engineering Directorate (PHED). The work required her to gather household-level information for Functional Household Tap Connections (FHTCs) under the State’s Jal Jeevan Mission programme. The task covered field surveys, geo-tagging, and entering data through mobile applications or physical forms, work that directly feeds into the State’s digital mapping and water-supply planning systems.

In her application, she explained how PHED functions as part of the State’s drinking-water delivery framework. Since her role was limited to data collection without supplying any goods or executing any works-contract components, she argued that the activity falls squarely within the “pure services” category. Being a service offered to a State Government department for a function listed in the Eleventh Schedule of the Constitution, she claimed exemption under Entry 3 of Notification 12/2017-CT (Rate).

Main Issue: Whether the service of collecting and geo-tagging household data for FHTC connections, supplied to the PHE Directorate, qualifies as “pure services” eligible for NIL GST under Entry 3 of Notification 12/2017-CT (Rate).

Authority Ruled: The AAR examined the work order, the nature of the activities, and the constitutional functions cited. It held that the PHE Directorate represents the Government of West Bengal, and the work relates directly to the supply of drinking water, a function assigned to Panchayats under Entry 11 of the Eleventh Schedule and to Municipalities under Entry 5 of the Twelfth Schedule. The Authority noted that all tasks involved data collection, mobile app usage, GIS inputs, and documentation without any transfer of goods. As such, the service satisfied the “pure service” requirement under the exemption notification.

The authority found that all three statutory conditions were fulfilled: pure service, supply to Government, and activity linked to constitutional water-supply functions, and it therefore ruled that the service is fully exempt from GST under Entry 3 of Notification 12/2017. Thus, the alternative question of classification and tax rate did not arise.

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