GST Exemption Denied: AAR Declines Ruling on Manpower Services Due to Pending Appellate Proceedings

The applicant, M/s Reliable Security and Intelligence Services (Orissa) Private Limited, has sought the Odisha Authority for Advance Ruling (AAR) Goods and Services Tax (GST) by filing an application dated September 18, 2025, under Section 97 of the CGST Act, 2017 read with Rule 104 of the CGST Rules, 2017 and Section 97 of the OGST Act, 2017 read with Rule 104 of OGST Rules, 2017, in FORM GST ARA-01. The case was heard on November 25, 2025.

The applicant is registered under the GST Act, with GSTIN 21AABCR8198L1ZY and possesses a principal place of business at Room No. 105, Barabati Stadium, Buxi Bazar, Cuttack, Odisha-753001.

The applicant is engaged in supplying manpower services to distinct organisations, including the Government Polytechnic, Bhubaneswar, RWSS Division, Office/Sub-Division Office across Odisha under the Addl Secretary to Government & Administrative Officers and OWSM. In respect of the services supplied by the applicant, the present advance ruling has been sought.

The applicant asked the following question, seeking the Odisha AAR:

• “Question: Whether supply of manpower service to both Government Polytechnic, Bhubaneswar and RWSS Division, Office/Sub-Division Office across Odisha under Addl Secretary to Government & Administrative Officers, OWSM are exempted from GST as per Sl. No. 03 of Notification No. 12/2017 -СT (Rate) dated 28.06.2017.“

The Odisha AAR has given the following ruling in the answer to the aforementioned question:

• Ruling: The Odisha Authority for Advance Ruling (AAR) Goods and Services Tax (GST) has denied giving any ruling on the present matter, holding that the questions raised by the applicant are already pending before the appellate authority under the CGST Act.

Refer to the official advance ruling for complete information.