In re Jay Kay Trans (GST AAR Tamilnadu)
The Authority for Advance Ruling, Tamil Nadu considered an application filed by M/s Jay Kay Trans, a proprietorship engaged in sanitation, solid waste management and urban cleanliness, concerning the classification and GST exemption applicable to services provided to the Greater Chennai Corporation (GCC).
The applicant had entered into an agreement dated 16.09.2025 with GCC for the upkeep and maintenance of burial grounds in Zones 6 to 10 for 12 months from 20.08.2025 to 19.08.2026. The contract required deployment of 262 personnel and supervisors, daily sweeping and cleaning of burial grounds, collection and disposal of waste, provision of rotomac and compactor bins, brooms, rakes, bleaching powder, lime powder and welfare items such as uniforms, gloves, masks, shoes, caps, PPE kits and raincoats. The contract value was Rs.8,54,91,000, inclusive of taxes.
The applicant sought a ruling on: (i) classification of the upkeep and maintenance services; and (ii) eligibility for exemption under Serial No. 3A of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as amended.
During the personal hearing, the applicant proposed classification under SAC 999424 – General Waste Collection Services, Others Not Elsewhere Specified. It submitted that the services constituted a composite supply of goods and services, with the value of goods below the prescribed 25% threshold. The applicant stated that the consumables and welfare items were used for performing the contract and that ownership or possession of such items was not transferred to GCC. A Chartered Accountant certificate was also submitted regarding the value of goods.
The jurisdictional State GST authority had proposed classification under the residuary SAC 9997, while stating that the applicant could qualify for the exemption subject to satisfaction of the 25% condition.
