In re Reliable Security And Intelligence Services (Orissa) Private Limited (GST AAR Odisha)
The applicant, a provider of manpower supply services to various government organizations such as Government Polytechnic, Bhubaneswar and RWSS Division offices across Odisha, filed an application seeking an advance ruling under the CGST and OGST Acts. The primary question raised was whether the supply of manpower services to these government entities is exempt from GST under Serial No. 03 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
The applicant stated that the recipient departments had refused to pay GST and sought clarification regarding the applicability of the exemption. The application was filed accordingly to determine the taxability of such services.
The jurisdictional tax authority opposed the admissibility of the application. It was submitted that a Show Cause Notice had already been issued against the applicant for non-payment of GST amounting to ₹1,07,51,771 for the period from 2017-18 to 2020-21. This demand, along with applicable interest and penalty, was subsequently confirmed by an Order-in-Original dated 31.12.2024.
The applicant, being aggrieved by the adjudication order, filed a writ petition before the High Court of Orissa on 01.05.2025. The matter was pending before the High Court at the time of consideration of the advance ruling application.
