No Ruling on GST on services to municipal corporation After Applicant Withdraws Plea

In re Cranberry Analytics Private Ltd (GST AAR Maharashtra)

The matter before the Authority for Advance Ruling, Maharashtra, involved an application filed under Section 97 of the CGST Act and MGST Act seeking clarification on GST applicability to services provided to a municipal corporation.

The applicant sought a ruling on whether its services were covered under clause 5 of the Twelfth Schedule of Article 243W of the Constitution of India and whether such services qualified as “pure services” eligible for exemption under Sr. No. 03 of Notification No. 12/2017-Central Tax (Rate). The issue was whether services rendered to a local authority in relation to functions entrusted under Article 243G/243W would attract a nil GST rate.

However, before any adjudication on merits, the applicant submitted an email dated 20 January 2026 stating that it no longer wished to pursue the questions raised and requested withdrawal of the application.

The Authority accepted the request, noting that the withdrawal was voluntary and unconditional. Accordingly, the application filed on 7 July 2025 was disposed of as withdrawn, without examining the merits or issuing any ruling on the issues raised.

FULL TEXT OF ORDER OF APPELLATE AUTHORITY OF ADVANCE RULING MAHARASHTRA

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

The present application has been filed under section 97 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017 [hereinafter referred to as “the CGST Act and MGST Act” respectively] M/s. Cranberry Analytics Pvt. Ltd., the applicant is seeking an advance ruling in respect of the following questions.

1. Whether the services provided by the applicant are covered under clause 5 of the twelfth schedule of Article 243W of the Constitution of India?

Whether the Chapter No. 99, Sr. No. 03 of the Notification No. 12/2017 Central Tax (Rate) as amended from time to time is applicable to the applicant for the pure services rendered to the Pimpri Chinchwad Municipal Corporation (Local authority) in relation to the functions entrusted to it under Article 243G/Article 243W of the Constitution of India, thereby categorizing the services under ‘Nil’ rate under GST?

The applicant submitted a letter via email dated 20.01.2026 and stated that they do not seek clarification on their questions and would like to withdraw the same. Hence, they requested to allow them to withdraw the subject application filed on 07.07.2025.

The request of the applicant to withdraw their application voluntarily and unconditionally is hereby allowed, without going into the merits or detailed facts of the case.

ORDER

(Under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017)

NO.GST-ARA-42/2025-26/B- 23 Mumbai, dt. 27.o1. 2026

The Application in GST ARA Form No. 01 M/s. Cranberry Analytics Pvt. Ltd., vide reference Online ARA Application Dated 07.07.2025 is disposed of, as being withdrawn