GST on Sewerage Water Treatment & Treated Water Supply by GVSCCL

In re Greater Visakhapatnam Smart City Corporation Limited (GST AAR Andhra Pradesh)

Authority for Advance Ruling (AAR) of Andhra Pradesh considered the application filed by M/s. Greater Visakhapatnam Smart City Corporation Limited (GVSCCL) under Section 97 of the Central Goods & Services Tax Act, 2017 (CGST Act) and Andhra Pradesh Goods & Services Tax Act, 2017 (APGST Act). The application sought clarity on the GST implications related to the treatment of sewerage water and the supply of treated water to industries by GVSCCL.

Background and Facts

GVSCCL, established as a Special Purpose Vehicle (SPV) under the Smart City Mission, is tasked with developing and managing infrastructure projects for Visakhapatnam. This includes the development of sewerage infrastructure and the treatment of sewage water. The Greater Visakhapatnam Municipal Corporation (GVMC), a local authority, had initially entered into agreements with Hindustan Petroleum Corporation Limited (HPCL) for the supply of clear water from various sources for industrial use.

Subsequently, under Government Order No. 546 issued by the Municipal Administration & Urban Development Department, Government of Andhra Pradesh, the responsibilities and projects related to water supply were transferred from GVMC to GVSCCL.

Issues Raised

The key issues raised by GVSCCL for advance ruling were:

1. Whether GST is applicable on the sewerage water treated by GVSCCL and the supply of treated water to industries.
2. If GST is applicable, what is the applicable tax rate.

Applicant’s Arguments

GVSCCL argued that the activity of supplying treated water falls under the definition of “supply” as per Section 7 of the CGST Act and APGST Act. They relied on Notification No. 2/2017-Central Tax (Rate) dated June 28, 2017, which provides exemption from GST for water other than aerated, mineral, purified, distilled, medicinal, ionic, battery, de-mineralized, and water sold in sealed containers. They contended that the treated water supplied by them did not fall under these exempt categories and therefore should be exempt from GST.

Authority’s Analysis and Decision

The AAR examined the provisions of the GST Acts and the specific notifications cited by GVSCCL. They observed that while the notifications exempt certain types of water, including natural water and water not treated for specific purposes, the treated water supplied by GVSCCL was specifically processed to meet industrial requirements. Therefore, it did not qualify for exemption under the mentioned notifications.

The AAR also noted that the supply of treated water by GVSCCL to HPCL for industrial use constitutes a taxable supply under GST. They referenced Schedule III of Notification No. 1/2017-Central Tax (Rate) dated June 28, 2017, which outlines the applicable GST rates for various goods and services. Water, including treated water, was subject to GST at the rate of 9% under this schedule.

Conclusion

Based on their analysis, the AAR concluded that:

1. GST is applicable on the supply of sewerage water treated by GVSCCL and the subsequent supply of treated water to industries.
2. The applicable GST rate for such supply is 9%, as per Schedule III of Notification No. 1/2017-Central Tax (Rate) dated June 28, 2017.

Summary

In summary, the AAR’s ruling clarifies that GVSCCL is liable to pay GST at the rate of 9% on the supply of treated water to industries, considering it does not fall under the exempt categories specified in GST notifications.

FULL TEXT OF THE ORDER OF AUTHORITY FOR ADVANCE RULING, ANDHRA PRADESH

(Under sub-section (4) of Section 98 of Central Goods and Services Tax Act, 2017 and sub-section (4) of Section 98 of Andhra Pradesh Goods and Services Tax Act, 2017)

1. At the outset we would like to make it clear that the provisions of CGST Act, 2017 and APGST Act, 2017 are in parimateria and have the same provisions in like matter and differ from each other only on a few specific provisions. Therefore, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act would also mean reference to the corresponding similar provisions in the APGST Act.

2. The present application has been filed u/s 97 of the Central Goods & Services Tax Act, 2017 and AP Goods & Services Tax Act, 2017 (hereinafter referred to CGST Act and APGST Act respectively) by M/s. Greater Visakhapatnam Smart City Corporation Limited (hereinafter referred to as applicant), registered under the AP Goods & Services Tax Act, 2017.

3. Brief Facts of the case:

1. M/s. Greater Visakhapatnam Smart City Corporation Limited, (Hereinafter referred to as “applicant”) It is a limited company incorporated under the Companies Act, 2013 at the city level, in which the state and the urban local body (GVMC) are the promoters with 50:50 equity share holding as per G.O.MS.No.43

2. In June 2015, the Government of India (“GOI”) initiated “Smart City Mission”, as a part of which Special Purpose Vehicles (“SPV”) are created. The SPVs will Plan, appraise, approve, release funds, implement, manage, operate, monitor and evaluate the Smart City development projects. Each Smart City will have a SPV which will be headed by a full time CEO and have nominees of Central Government, State Government and Urban Local Bodies (“ULB”) on its Board. d. GVSCCL is one of such Special Purpose Vehicles (SPV).

3. The Vizag (Visakhapatnam) Municipality was set up as early as in 1858. The Vizag (Visakhapatnam) Municipality was formed in order to fulfill the basic infrastructural needs of the people and was converted into Municipal Corporation in 1979 (Hereinafter Referred to as GVMC). GVMC is a “local authority”. The GVMC, under Article 243W of the Constitution of India, read with 12th Schedule to the Constitution, is required to provide the services of management of sewage system for the city of Visakhapatnam.

4. This purpose, GVMC intends to develop a sewerage infrastructure project in Visakhapatnam, comprising.

i. Laying of sewerage network and providing connections in Gajuwaka, Malkapuram and Pendurthi in a phased manner;

ii. Full utilisation of the existing 108 MLD Sewage Treatment Plant (STP) at Narava,

iii. Augmentation of the existing sewerage pumping stations and development of new sewage pumping stations as required;

iv. Development of a new waste water treatment plant with a system for additional treatment to further treat the treated waste water from the STPs for the SUPPLY OF RECYCLED WATER (Hereinafter referred to as PRODUCT) TO VARIOUS INDUSTRIES IN VISAKHAPATNAM (Hereinafter referred to as the “PROJECT”)

5. GVMC has entered into agreements with M/s Hindustan Petroleum Corporation Limited (Hereinafter referred to as “HPCL”) for SUPPLY OF RECYCLED (TREATED) WATER while discharging its duties under Article 243W of the Constitution of India, read with 12th Schedule to the Constitution. The details of which are as following:

i. Agreement No 26/GVMC-Bulk Water/2017-18, dated 11-01-2018 for the supply of 12 LIGD of clear water by GVMC from its Raiwada source to HPCL for use at its Visakh Refinery;

ii. Agreement No 26/GVMC-Bulk Water/2017-18 dated 11-01-2018 for the supply of 18 LIGD of clear water by GVIMC from its Meghadri Gedda Reservoir to HPCL for use at its Visakh Refinery’ and;

iii. Agreement No. 27/GVMC-Bulk water/2017-18 dated 11-01-2018 for the supply of 15 LIGD of clear water by GVMC from its Thatipudi Source to HPCL for use of 14 LIGD at its Visakh Refinery and 1 LIGD at its Waltair Park Housing Complex

6. The purpose of undertaking several obligations pertaining to the development of Visakhapatnam as a Smart City Further, vide the G O Rt No 546 dated 26-07-2017 issued by the Municipal Administration & Urban Development Department, GoAP, the ‘PROJECT’ had been transferred from GVMC to GVSCCL for development and further operations.

7. In line with G O Rt No 546 dated 26-07-2017 issued by the Municipal Administration & Urban Development Department, Go AP, a TRIPARTITE AGREEMENT FOR THE SUPPLY OF BULK WATER TO HPCL had been executed on 29th March, 2019 between GVSCCL, and HPCL in which the parties agreed that the rights and obligations of GVMC Under the Executed Agreements shall stand transferred and novated in favour of GVSCCL pursuant to this Agreement and that GVSCCL shall undertake, comply with and perform the said obligations of GVMC under the Executed Agreements.

8. Post novation of the rights and obligations of GVMC in favour of GVSCCL pursuant to current agreement, the Parties now agree to the following revised understanding in relation to the supply of water to HPCL:

i. Instead of clear water supply from GVMC as per the Previously Executed Agreements, HPCL has agreed to accept 36.2 LIGD (16 46 MLD) of Product from GVSCCL, which GVSCCL shall supply to HPCL at the rate of Rs. 57/- per KL (inclusive of all taxes & charges as applicable). Cost to HPCL for the Product will be only Rs 57/- per KL (all inclusive).

ii. In addition to the above, HPCL has requested and GVSCCL has agreed to supply additional 30 LIGD (13.64 MLD) of Product to HPCL Thus, a total of 66.20 LIGD (30.10 MLD) [36.2 LIGD (16.46 MLD) + 30 LIGD (13.64 MLD)] of Product water shall be supplied by GVSCCL to HPCL at the rate of Rs. 57/- per KL (inclusive of all taxes & charges as applicable) Cost to HPCL for the Product will be only Rs. 57/-per KL (all inclusive)

iii. Balance 8.8 LIGD (4 MLD) of clear water (hereinafter referred to as the “Clear Water”) shall continue to be supplied by GVMC to HPCL, at the current rate of Rs 60/- per KL (as per the Executed Agreements) or at such revised rates as may be applicable from time to time.

iv. It is the responsibility of the applicant (M/s GVSCCL) to discharge taxes if any on the supply of recycled (treated) water supplied to HPCL.

v. In this regard the Applicant prays to know the applicability of GST on the revenue earned through supply of Recycled Water to various industries by GVSCCL.

vi. If the answer to above is affirmative, rate of tax applicable on the above mentioned supply.

4. Questions raised before the authority:

The applicant sought advance ruling on the following:

1. Whether GST applicable on the Sewerage water treated by GVSCCL and supply of Treated Water to various industries by GVSCCL.?

2. If yes, The rate of Tax applicable?

On Verification of basic information of the applicant, it is observed that the applicant is under State jurisdiction i.e ,Siripuram circle, Visakhapatnam Division. Accordingly, the application has been forwarded to the jurisdictional officer and a copy marked to the Central Tax authorities to offer their remarks as per Sec. 98(1) of CGST /APGST Act 2017.

In response, remarks are received from the State jurisdictional officer concerned stating that no proceedings lying pending with the issue, for which the advance ruling sought by the applicant.

5. Applicant’s Interpretation of Law:

The applicant submitted the following legal provisions to advance his arguments;

1. Applicant understands that levy and collection of the CGST is governed by the Central Goods and Services Tax Act, 2017 (hereinafter referred to as the ‘CGST Act’) and levy and collection of SGST is governed by respective state GST Acts [Andhra Pradesh Goods and Services Tax Act (APGST), 2017 for the state of Andhra Pradesh]. Similarly, levy and collection of IGST are governed by Integrated Goods and Services Act, 2017 (hereinafter referred to as the ‘IGST Act’). Hereinafter, the reference to Central Goods & Services Tax Act, 2017 or CGST Rules, 2017 may be considered as a reference to APGST Act, 2017 or AP GST rules, 2017 or IGST Act, 2017 also as it contains similar provisions

2. Applicant understands that the activity undertaken by Applicant falls within the scope of the ‘supply’ as defined under Section 7 of CGST Act, 2017 (which was made applicable to IGST) and also under Section 7 of AP GST Act, 2017.

3. Notification No. 1/2017-C.T (Rate) dt.28 06.2017 was issued to prescribe rare of tax under the CGST Act. Similar notifications are also issued under the SGST and IGST Acts for prescribing rate of tax on supply of goods and services under relevant Acts. Entry relating to water was notified in Schedule Ill of the Notification at Serial No. 24. The entry in notification is reproduced below:

S.No	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)
24	2201	Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured	9

4. Entry 24 of Schedule Ill of Notification No. 1/2017 C.T.(Rate) dtd. 28-06- 2017 which relates to “Water” was subject to amendment vide Notifications No. 06/2018-C.T. (Rate), dt. 25-01-2018. Also new entry relating to water was inserted vide same Notification at Sr. No. 46B of Schedule If of the Notification. Effect of all above-mentioned notification w.e.f. 25,01.2018 on the entry 24 of Notification No. 1/2017 Central Tax (Rate) is as under:

S.No	Schedule	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)	(5)
46B	II	2201	Drinking water packed in 20- liter bottles	6
24	III	2201	Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured	9

#combined rate (SGST& CGST)/ IGST is 12% and 18% respectively.

5. Notification No, 02/2017-Central Tax (Rate), dt. 28-06-2017 was issued to notify the exemptions on supply of goods under CGST Act. Entry relating to water was notified at Serial No. 99 of the Notification. The same is reproduced below: –

S.No	Chapter Heading / Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)
99	2201	Water [other than aerated, mineral, purified, distilled, medicinal, ionic, battery, de-mineralized and water sold in sealed container]	Nil

The combined reading of entries in, Notification No.1/2017 C.T. dt.28.06.2017 Notification No.2/2017 C.T.(Rate) dt.28.07.2017, make it clear that the Treated Sewerage Water is not natural water but just water treated to suit the purpose of HPCL is exempt from tax. The applicant is receiving Sewage Water and treating the same to suit the industrial needs. Thus, the water supplied by applicant to HPCL is exempt from tax.

6. The Sewerage water treated by GVSCCL doesn’t fit the definition of Purified water as per the “the common parlance test” for finding the meaning of the term “purification”, it has been submitted that the term “purified water” means water for human consumption, which is not the case here.

7. Under Notification No. 12/2017 Central Tax (Kate) dtd.28.06.2017 supply of certain services is exempt from tax. The entry-3 of the said notification is produced below: –

S.No	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)
3	Chapter 99	Pure services (excluding works contract service or other composite supplies involving supply of any goods) provided to the Central Government, State Government or Union Territory or Local Authority or a Government Authority by way of any activity in relation to any function entrusted to a Panchayat under Article 243G of the Constitution or in relation to any function entrusted to a Municipality under Article 243W of the Constitution	Nil

8. We also rely on the Government Clarification that its intention of not levying GST on the supply of general-purpose water by way of issuance of the CBIC Circular No. 52/26/2018 dated 09 August 2018, wherein it has been clarified that supply of drinking water, for public purposes, if not supplied in sealed containers, is exempted from GST

9. Thus, by applying the canon of “purposive construction”, which gives effect to the legislative purpose/intendment, applicant is of the view that the Treated water supplied by it to HPCL for Industrial purpose is eligible for exemption under the relevant entry at SI. No. 99 of the exemption notification no. 02/2017-C.T. (Rate) dated 28.06.2017

6. Personal Hearing:

The proceedings of Personal Hearing was conducted on 02.04.2024, for which the authorized representative, M.Ravi Teja, Charted Accountant and K.Malikarjun, Charted Accountant and reiterated the submissions already made.

7. Discussion and Findings:

We have examined the issues raised in the application in light of the facts and arguments submitted by the applicant. We have considered the submissions made by the applicant in their application for Advance Ruling. We have considered the issues involved from which advance ruling is sought by the applicant and the relevant facts along with arguments made by the applicant and also their submissions made during the time of the personal hearing.

M/s. Greater Visakhapatnam Smart City Corporation Limited, it is a limited company incorporated under the Companies Act, 2013 at the city level, in which the state and the urban local body (GVMC) are the promoters with 50:50 equity share holding as per G.O.MS.No.43. The Vizag (Visakhapatnam) Municipality was formed in order to fulfill the basic infrastructural needs of the people and was converted into Municipal Corporation in 1979 (Hereinafter Referred to as GVMC). GVMC is a “local authority”. The GVMC, under Article 243W of the Constitution of India, read with 12th Schedule to the Constitution, is required to provide the services of management of sewage system for the city of Visakhapatnam.

The applicant submitted that the GVMC has entered into agreements with M/s Hindustan Petroleum Corporation Limited (Hereinafter referred to as “HPCL”) date:29-03-2019 for SUPPLY OF RECYCLED (TREATED) WATER while discharging its duties under Article 243W of the Constitution of India, read with 12th Schedule to the Constitution.

The GVMC and HPCL have executed 3 agreements for the supply of Bulk Water as per the following details:

i. No 25/GVMC-Bulk Water/2017-18, dated 11-01-2018 for the supply of 12 LIGD of clear water by GVMC from its Raiwada source to HPCL for use at its Visakh Refinery;

ii. Agreement No 26/GVMC-Bulk Water/2017-18 dated 11-01-2018 for the supply of 18 LIGD of clear water by GVIMC from its Meghadri Gedda Reservoir to HPCL for use at its Visakh Refinery’ and;

iii. Agreement No. 27/GVMC-Bulk water/2017-18 dated 11-01-2018 for the supply of 15 LIGD of clear water by GVMC from its Thatipudi Source to HPCL for use of 14 LIGD at its Visakh Refinery and 1 LIGD at its Waltair Park Housing Complex.

The applicant is total quantity agreed to be supplied by GVMC to HPCL under the aforesaid Agreements is 45 LIGD (20.46 MLD). In terms of these Executed Agreements, GVMC is already supplying 45 LIGD (20.46 MLD) of the clear water to HPCL. However, going forward, once the project Facility is operational, GVSCCL shall supply 36.2 LIGD ( 16.46 MLD) of Recycled (treated) water (hereinafter referred to as the Product) which shall replace 36.2 LIGD (16.46 MLD) of clear water being supplied by GVMC presently and GVMC shall continue to supply only 8.8 LIGD (4 (MLD) of clear water to HPCL.

The applicant has raised a specific questions asked about such ‘treated water’ which is the forward supply of the applicant. We find that ‘water’ is covered under Chapter heading 2201 of GST Tariff. We also find that there are two schedule entries for ‘water’ under Chapter heading 2201 under the CGST Act. The first entry no.99 of the Notification no.02/2017 Central Tax (Rate), Dt.28-06-2017 which is an exemption notification. The second is Entry No. 24 of the Notification No.01/2017 – Central Tax (Rate) dt.28-06-2017.

Notification No, 02/2017-Central Tax (Rate), dt. 28-06-2017 was issued to notify the exemptions on supply of goods under CGST Act. Entry relating to water was notified at Serial No. 99 of the Notification. The same is reproduced below: –

S.No	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)
99	2201	Water [other than aerated, mineral, purified, distilled, medicinal, ionic, battery, de-mineralized and water sold in sealed container]	Nil

The aforesaid entry at Sr. No. 99 reveals that, Chapter heading 2201 covers “water” other than aerated, mineral, purified distilled, medicinal, ionic, battery, de-mineralized and water sold in sealed container. The said entry and HSN speaks about only “water” wherein other category of waters mentioned therein, are not provided exemption from tax. The said entry therefore covers simple and natural type of water and further it does not contain water which has been subject to processes like purification etc.

Supply Price for the product and clear water

a) supply by GVSCCL (product)

• The Supply Price of the Product payable by HPCL to GVSCCL for the supply of the Product will be Rs. 57/- per KL (inclusive of all taxes & charges as applicable). Cost to HPCL for the product will be only Rs. 57/- per KL (all inclusive) from the Effective Date.
• HPCL shall be charged for at least 60 % of the Contracted Quantity of Product per month (Contracted Quantity of Product per month is defined as 66.2 LIGD (30.10 MLD x number of days in that particular month if the quantity of Product consumed in a month is less than 60% of the Contracted Quantity of Product in a month
• For the quantity of Product consumed over and above the Contracted Quantity of Product in a month, HPCL shall be charged for the extra quantity at the same price as the Supply Price of the Product.
• The Supply Price shall escalate every year on 1s April as per the Whole Sale Price Index (WPI) applicable from the successive year after effective date.
• The escalation provision for Supply Price of the Product shall be such that at any point of time, the Supply Price of the Product shall not exceed the respective Supply Price of the Clear Water by GVMC applicable at that point of time. The price of the Product at any point of time shall be the with respect to Supply Price of Clear Water.

b) Supply by GVMC (Clear Water)

• The Supply Price of Clear Water to be supplied by GVMC to HPCL shall be. Calculated at the rate of Rs. 60/- per KL or at such rate as may be applicable from time to time.
• HPCL will be charged for at least for 60% of the Contracted Quantity of Clear Water per month if the Contracted Quantity of Clear Water consumed in a month is less than 60% of Contracted Quantity of Clear Water.
• HPCL will be charged for actual quantity of Clear Water consumed in a month if it varies between 60% and 100% of Contracted Quantity of Clear Water, reckoned per month at the rate of Rs.60/- per KL or at such rate as may be applicable from time to time.
• HPCL will be charged for additional Clear Water quantity consumed, over and above the Contracted Quantity of Clear Water, reckoned per month at the rate of Rs. 120/- per KL.
• HPCL will be charged for actual consumption of Clear Water even though it is less than the 60% of Contracted Quantity of Clear Water reckoned per month, if GVMC is solely responsible for supply of less than 60% of Contracted Quantity of Clear Water.
• HPCL will be charged for maintenance of meters, instrumentation and automation etc. at the rate of 0.75% af the monthly bill, which is subject to revision as and when necessary.

• The existing rate per KL of Clear Water consumed shall be revised as and when deemed necessary by the governing council of GVMC from time to time.
• HPCL will be informed of the revision in Supply Price well in advance by 2 months by directly addressing through a letter
• The Clear Water supply bye-laws as framed and amended from time to time by the GVMC shall form part of this Agreement to the extent they are consistent with the provisions hereof.

The second Entry No.24 prescribed in Schedule III of Notification No.01/2017- Central Tax (Rate) Dt.28.06.2017 is reproduced as below:-

S.No	Schedule	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)	(5)
24	III	2201	Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured	9

It is further observed that the said Entry 24 of schedule III of Notification No.01/2017 which relates to “Waters” was amended vide Notification No.06/2018- Central Tax (Rate), Dt.25-01-2018. Also, new entry relating to water was inserted to water was inserted vide the said amendment Notification at Sl.no. 46 B of Schedule of the Notification. Effect of all above mentioned notifications with effect from 29.02.2018 is reproduced as under:

S.No	Schedule	Chapter /Heading /Subheading /Tariff item	Description of Goods	Rate %
(1)	(2)	(3)	(4)	(5)
46B	II	2201	Drinking water packed in 20-liter bottles	6
24	III	2201	Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured	9

On the perusal of above these notification entries, it is found that, Drinking Water packed in 20 liters bottles” are liable to tax 12% and the *Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar on other sweetening matter nor flavored are taxable and liable lo tax @ 18% GST

In the subject case, the water supplied by the applicant to GVMC is obtained after the treatment to sewage water as submitted by the applicant and the said water is not potable. Hence Entry no. 46 B which pertains to drinking water only, is not applicable to the impugned product.

Entry No. 24 of Schedule III of Notification No. 01/2017-CT. (Rate) dated 28.6.2017, as amended, uses the word “Waters” including natural or artificial mineral waters and aerated waters not containing added sugar or other sweetening matter nor flavored. The words ‘waters’ is used in plural form and further specifically mentions inclusion of different type of waters which are to be covered under the said St. No. 24. Thus, it is clear that different type of waters are covered in Entry No. 24, prescribed as “waters” and the same excludes the entries of ‘water’ covered under Sr. No. 99 of Notification No. 02/2017-C.T. (R) dated 28.06.2017 and Entry 46B of Schedule II of Notification No. 06/2018-C.T. (Rate) dated 25.01.2018.

In view of the above discussions, we agree with views of applicant and hold that the impugned goods, called as “Sewerage Treated Water”, is purified water.

In view of the above discussions, we pass an order as follows:

RULING

(Under Section 98 of Central Goods and Services Tax Act, 2017 and the Andhra Pradesh Goods and Services Tax Act, 2017)

Question: Whether GST applicable on the Sewerage water treated by GVSCCL and supply of Treated Water to various industries by GVSCCL?

Answer : The impugned goods i.e water , subject to the specification and utility submitted by the tax payer falls under Sr. No. 99 of Notification No. 02/2017-C.T. (R) dated 28.06.2017

Question: If yes, the rate of Tax applicable

Answer : The rate of tax NIL as per Notification No. 02/2017-C.T. (R) dated 28.06.2017 Subject from amended time to time