GST Vidhi | GST Advance Ruling


Srinacss Enviro Private Limited Vs. Tamil Nadu Authority for Advance Ruling (TN-AAR) (Advance Ruling No. 13/ARA/2025)

GST on Housekeeping Services provided to Indian Institute of Information Technology, Design and Manufacturing (IIITDM), Kancheepuram

Summary of Advance Ruling:

The applicant sought a ruling on whether their housekeeping/cleaning services provided to IIITDM Kancheepuram, an institute of national importance funded by the Government of India, are exempt from GST under Notification No. 13/2023-CT(Rate), dated 19.10.2023 or under any other exemption.

The Authority ruled that such services are taxable, and the applicant cannot raise invoices without charging GST.

Ruling Number: Advance Ruling No. 13/ARA/2025

Date of Ruling: 29 April 2025

Ruling Authority: Tamil Nadu Authority for Advance Ruling (TN-AAR)

Name of Applicant: M/s. Srinacss Enviro Private Limited

Questions Raised in the Application:

1.    Whether cleaning and sanitary services under “Housekeeping” provided to IIITDM Kancheepuram are exempt from GST?

2.    Whether the letter from IIITDM dated 09.05.2024 justifying exemption under Notification No. 13/2023-CT(Rate) is valid?

3.    Whether it is lawful to raise invoice without charging GST based on the Institute’s request?

Relevant Sections / Notifications:

  • Section 97(2)(b) & (e) of CGST Act, 2017 – Grounds for seeking ruling
  • Notification No. 13/2023-CT (Rate) dated 19.10.2023 – Inserts Entry 3B in Notification No. 12/2017
  • Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017
  • Clause (zf) – Definition of “Governmental Authority”
  • Sl. No. 66 of Notification No. 12/2017 – Exemption to educational institutions

Submission by the Applicant:

  • The applicant provides environmental services, including cleaning, toilet cleaning, gardening, and security.
  • IIITDM is a Government of India-established institute.
  • Based on Notification No. 13/2023, IIITDM has requested them not to charge GST on invoices.
  • They classified IIITDM as a Governmental Authority and the services as sanitation.

Documents Submitted:

  • Tender and work order
  • IIITDM’s letter dated 09.05.2024
  • Notification No. 13/2023

Discussion and Findings by AAR:

1.    Nature of Services:

o   Applicant is providing housekeeping/cleaning services, not sanitation, water supply, or solid waste management.

o   Invoices refer to “Cleaning Service Charges” and “Manpower supply at Admin & Academic Blocks.”

2.    Notification 13/2023 – Entry 3B:

o   Grants exemption for services like sanitation, water supply, solid waste management, etc., provided to Governmental Authorities.

o   IIITDM does not qualify as a “Governmental Authority” under clause (zf) of Notification 12/2017, since it does not carry out municipal or panchayat functions under Articles 243W or 243G.

3.    Educational Institution Exemption (Sl. No. 66):

o   Available only to institutions providing education up to higher secondary level.

o   IIITDM is a higher education institution – not eligible for this exemption.

4.    Misinterpretation by IIITDM:

o   IIITDM's request to raise invoice without GST based on sanitation exemption is misplaced.

o   Housekeeping is not equivalent to sanitation services for exemption purposes.

Answers to Questions:

1.    No, the housekeeping/cleaning services provided to IIITDM are not exempt from GST.

2.    The letter from IIITDM dated 09.05.2024 does not justify exemption under Notification 13/2023.

3.    It is not lawful for the applicant to raise invoice without charging GST for such services.

Conclusion:

  • The services rendered by M/s. Srinacss Enviro Pvt. Ltd. to IIITDM are purely housekeeping/cleaning in nature.
  • IIITDM does not qualify as a “Governmental Authority” under GST law.
  • Notification No. 13/2023 and Sl. No. 66 of Notification No. 12/2017 do not apply.
  • Therefore, the applicant must charge GST on invoices raised for such services.

Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.

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