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GST : Consultancy services provided by applicant for upgrading of State Highways and major District Roads, are not in relation to any function entrusted to any Panchayat or Municipality under Article 243G and Article 243W of Indian Constitution respectively and, thus, benefit of exemption from tax in terms of Sl. No. 3 of Notification No. 12/2017-Central Tax (Rate), dated 28-6-2017 is not available to applicant