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2024 (2) TMI 1356 - AAAR - GSTScope of Advance Ruling - Service recipient is Government Entity or not - services provided by the Appellant in respect of work order No. TN-483 for Operation and Maintenance of identified 33/11 KV Grid Sub-Stations to Jaipur Vidyut Vitran Nigam Limited - exempt vide serial number 3 of Notification No. 12/2017 - Central Tax (Rate) dated 28.06.2017 or not - HELD THAT:- The law covers two kinds of supplies under the purview of the AR mechanism : (i) Supplies being undertaken - meaning thereby supplies which have begun, but not concluded. Once the supply has been concluded, it will cease to be covered by the term “being undertaken''; (ii) Proposed to be undertaken - in the instant ease the supplies have already been concluded. Thus, as the name implies, the pronouncement with respect to them shall no longer be in the nature of “Advance”. As such, these supplies cannot be covered by the Advance Ruling Mechanism. The Authority for Advance Ruling, Rajasthan is right on not pronouncing the Ruling on Merits. Further, the Appellant has contended that they are engaged in such work/supply regularly and wanted to know the taxability of the transaction for future references. In this context, it is found that the impugned Ruling has been sought only for the specific Work Order No TN-483 for Operation and Maintenance of identified 33/11 KV Grid Sub-Stations awarded by Jaipur Vidyut Vitran Nigam Limited to the appellant. Supplies under the work order have been undertaken during the period from 01.11.2019 to 30.04.2021. It is not in dispute that the supply has already been completed. Thus, the question of entertaining any application subsequent to the period for which supply has already been completed, does not arise. The Ruling pronounced by the Authority for Advance Ruling. Rajasthan vide Order dated 01.06.2021 is right and needs no interference at this forum and the same is upheld.
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