Rajasthan GST Advance Ruling RAJ/AAR/2023-24/03: Application Withdrawn
The Authority for Advance Ruling allowed the applicant to withdraw their request, meaning no decision was made on the tax exemption.
- Ruling
- RAJ/AAR/2023-24/03 Dated 25.04.2023
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- Nabard Consultancy Services asked if their services were exempt from GST.
- The company later requested to withdraw their application.
- The Authority for Advance Ruling granted the withdrawal request.
- No legal decision was issued regarding the taxability of these services.
In short
Nabard Consultancy Services asked the Rajasthan Authority for Advance Ruling (AAR) whether their agricultural consultancy services provided to a government body were exempt from Goods and Services Tax (GST). Before the authority could decide, the company asked to withdraw their application because their clients agreed with their tax position. The authority accepted this request and closed the case without issuing a ruling.
What has changed
How it worked before
Businesses often seek an advance ruling to get certainty on whether a specific service qualifies for a tax exemption under Notification No. 12/2017-CGST.
What has changed
Nothing changed because the authority did not issue a decision. The legal question of whether these specific consultancy services are exempt remains unanswered by this ruling.
Who this affects
Consultancy firms providing services to government entities who are unsure about their GST exemption status.
An example
Imagine a private firm provides project management services to a state water department. They might wonder if they qualify for the same exemption Nabard Consultancy Services originally asked about. Because this ruling was withdrawn, the firm cannot use it as proof that their services are exempt. They must still evaluate their own contract and tax position independently.
What you should do
Do not rely on this order to determine your own tax liability. An advance ruling is only binding on the business that requested it and their specific tax officer; since this case was withdrawn, it provides no legal guidance for other businesses.
If you do nothing
If you assume this order confirms an exemption, you risk underpaying your GST. If a tax officer disagrees with your interpretation, you may face demands for unpaid tax, interest, and penalties. Always seek professional advice based on your specific contract rather than relying on withdrawn or unrelated rulings.
The terms explained
- Advance Ruling
- A formal decision from tax authorities that clarifies how GST laws apply to a specific business transaction.
- Exemption
- A provision in the tax law that allows certain goods or services to be supplied without charging GST.
- Notification No. 12/2017-CGST
- A specific government order that lists various services that are exempt from paying GST.
The ruling in detail
Authority for Advance Ruling
M/s NABARD CONSULTANCY SERVICES PRIVATE LIMITED
RAJ/AAR/2023-24/03 Dated 25.04.2023 · Rajasthan
Questions before the authority
- whether the services supplied by us are eligible for exemption per Entry 3 of Notification No. 12/2017-CGST (Rate) after 01 January 2022, if not what will be the tax rate
Facts
The applicant is engaged in providing consultancy services in the agriculture and rural sector. They entered into a memorandum of understanding with WSSO, an organization under PHED, and sought a ruling on whether their services to this government entity were exempt under Entry 3 of Notification No. 12/2017-CGST. Subsequently, the applicant requested to withdraw their application as their customers accepted their understanding regarding GST applicability.
Ruling
The authority allowed the request for withdrawal of the application. Consequently, no ruling was provided on the merits of the taxability or exemption of the services.
Reasoning
The applicant filed a letter dated 18.04.2023 requesting to withdraw the Advance Ruling application. The authority considered this request and decided to allow the withdrawal. As a result, the authority did not proceed to provide a ruling on the questions raised.
Provisions relied on
- Section 97(2) of CGST/SGST Act, 2017
- Notification No. 12/2017-CGST
For the practitioner
This order is **procedural only** and does not provide any substantive interpretation of the law regarding the exemption of consultancy services provided to government entities. It serves as a record that the applicant chose to **withdraw their application** before a ruling was issued, meaning the legal issue remains undecided by this authority.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/raj_aar_order_no._03-2023-34_of_nabard_consultancy_services_private_limited.pdf
Legibility of the scan, as read: high.
Prepared 20-10-2026.
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