AAR Grants Full GST Exemption to PHED Data Validation & Jal Jeevan Mission Support Services

Amit Kumar Mukherjee, a GST-registered service provider, is engaged in field-level data validation work for Functional Household Tap Connections (FHTCs) under various Piped Water Supply Schemes implemented by the Public Health Engineering Directorate (PHED), Government of West Bengal. His work involves verifying photographic records, removing duplicate entries, cross-checking household data with electricity connections or other unique documents, and creating accurate, error-free databases. He also conducts orientation and training programmes on assessing functionality through the Jal Mitra web and mobile applications, along with evaluating performance under Jal Jeevan Mission (JJM) support activities.

He approached the Authority for Advance Ruling seeking clarity on whether these services, when supplied to PHED, qualify as exempt “pure services” under Serial No. 3 of Notification No. 12/2017–Central Tax (Rate), being activities connected with functions entrusted to Panchayats and Municipalities under Articles 243G and 243W of the Constitution.

Main Issue: Whether data validation, GIS mapping, digital asset management, training programmes, and functionality assessment services provided to PHED in relation to water-supply networks qualify as exempt “pure services” under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate).

AAR Held: The Authority held that all services rendered by the applicant were purely service-based, with no supply of goods and no element of works contract or composite supply. The Authority noted that the activities were closely linked to the implementation and monitoring of safe drinking-water supply under the Jal Jeevan Mission and directly related to constitutionally assigned functions, namely drinking water under the Eleventh Schedule to Article 243G and water supply under the Twelfth Schedule to Article 243W.

Since the services were provided to the Government of West Bengal through its PHED Directorate and were essential for validating, mapping, and managing piped water supply schemes across the State, all conditions under Serial No. 3 of Notification No. 12/2017-Central Tax (Rate) stood satisfied. The Authority therefore ruled that the services qualify as “pure services” and are fully exempt from GST, making any discussion on alternative classification or tax rate unnecessary.

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