9911796707
TMI Blog2025 (3) TMI 162X X X X Extracts X X X X X X X X Extracts X X X X ..... to such dissimilar provisions, a reference to the CGST Act would also mean reference to the corresponding similar provisions in the WBGST Act. Further to the earlier, henceforth for the purposes of these proceedings, the expression "GST Act" would mean the CGST Act and the WBGST Act both. 1.2 The applicant is a Co-operative Society registered under the West Bengal Co-operative Societies Registration Act. The applicant provides multipurpose services including supply of manpower support services to various Government Departments under M/s Webel Technology Limited (WTL, for short). The applicant has received a work order from WTL for providing manpower services to the Public Health Engineering Directorate of the Government of West Bengal for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed application before the Hon'ble West Bengal Authority for Advance Ruling as to whether the supply of pure labour to the Government is exempted or not. * The Advance Ruling authority has passed an order in favour of Webel Technology Limited that their supply to Public Health Engineering Department, Government of West Bengal is exempted from payment of tax. * On the contrary, in the case of applicant, the exemption is not allowed by the Advance Ruling authority. * Thus, the applicant has sought rectification and requested to allow the exemption to the applicant also as provided to Webel Technology Ltd. 1.6 In connection to the application for rectification, the applicant has been allowed an opportunity of being heard. Mr Goutam C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sioner, CGST & CX, Bidhannagar Division, Kolkata North Commissionerate has submitted that the relief sought by the applicant is of the nature of merit which is a subject of interpretation of law and therefore the applicant is not entitled to seek rectification under section 102 of the GST Act. 1.10 We are also of the same view as expressed by the officer concerned from the revenue that the issue raised by the applicant is a matter of legal interpretation and this authority, after a detailed discussion, has pronounced the ruling. The applicant, being aggrieved by the ruling, may approach before the Appellate Authority under section 100 of the GST Act. There is no scope to invoke the provision of section 102 in the instant case. 1.11 In lig ..... X X X X Extracts X X X X X X X X Extracts X X X X
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