GST Exemption for Solid Waste Management Services to Government Entities
The Kerala Authority for Advance Ruling confirmed that solid waste management services provided to government-owned companies are exempt from GST.
- Ruling
- ADVANCE RULING No. KER/33/2025 Dated 10.10.2025
- Dated
- 10 Oct 2025
- 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
- Tiffot Private Limited asked if their waste management services were GST exempt.
- The Authority ruled these services are exempt under Notification No. 13/2023.
- Clean Kerala Company Limited qualifies as a Governmental Authority.
- The services relate to municipal functions listed in the Constitution.
In short
The company asked if their waste management services for a government-owned entity were exempt from Goods and Services Tax (GST). The Authority confirmed that because these services support municipal functions, they qualify for a tax exemption.
What has changed
How it worked before
It was previously unclear if all government-owned companies qualified as 'Governmental Authorities' for the purpose of this specific GST exemption.
What has changed
The ruling clarifies that private contractors performing solid waste management for government-owned entities can claim a nil tax rate. This confirms that such work is treated as a public service rather than a taxable commercial supply.
Who this affects
Private waste management companies and contractors providing services to government-owned entities.
An example
A private firm in another state collects plastic waste for a government-owned water board. They might wonder if this ruling applies to them. While this ruling provides a helpful perspective, they should consult their own tax advisor to confirm if their specific contract meets the same criteria.
What you should do
If you provide similar services, review your contract to see if your client qualifies as a Governmental Authority. Remember that an Advance Ruling only binds the company that asked and its specific tax office; it is not a general law that applies to your business automatically.
If you do nothing
If you assume this ruling applies to you and stop paying GST without a specific order for your own business, you risk a tax demand. A tax officer may disagree with your interpretation, leading to penalties and interest charges. Always seek professional advice before changing your tax filing position.
The terms explained
- Governmental Authority
- An entity established by the government that is responsible for carrying out specific public or municipal functions.
- Entry 3B of Notification No. 13/2023
- A specific section of tax law that lists services provided to government bodies that are exempt from GST.
- Twelfth Schedule
- A list in the Constitution of India that defines the functions and responsibilities of local municipal bodies.
The ruling in detail
Authority for Advance Ruling
TIFFOT PRIVATE LIMITED
ADVANCE RULING No. KER/33/2025 Dated 10.10.2025 · Keralam
Questions before the authority
- Whether the solid waste management services rendered by Tiffot Private Limited to Clean Kerala Company Limited, including the collection, storage, transportation, processing, and bundling of non-recyclable plastic waste for co-processing, are exempt from GST under Entry 3B of Notification No. 13/2023 - Central Tax (Rate) dated 19th October 2023, considering that the recipient is a Governmental Authority?
- Further, in case such services are not explicitly covered under the aforementioned notification, whether they may qualify for GST exemption under any other notifications or circulars issued under the CGST Act, 2017, specifically where services provided to governmental authorities for public sanitation or environmental protection are covered?
Facts
The applicant is engaged in solid waste management services, specifically the collection, handling, storage, bundling, transportation, and final disposal of non-recyclable plastic waste. They operate under a work agreement with Clean Kerala Company Limited (CKCL), a public sector undertaking wholly owned by the Government of Kerala. The applicant performs these services to assist CKCL in fulfilling its statutory obligations regarding scientific waste management.
Ruling
| Question | What the authority ruled |
|---|---|
| Exemption for solid waste management services to CKCL | Exempt from GST Under Entry 3B of Notification No. 13/2023 - Central Tax (Rate) dated 19th October 2023 |
| Alternative exemption for services to governmental authorities | Void ab initio Not applicable as the services are covered under Entry 3B |
The Authority ruled that the services provided by the applicant to CKCL are exempt from GST under Entry 3B of Notification No. 13/2023 - Central Tax (Rate). Because the services were found to be covered under this specific entry, the second question was declared void ab initio.
Reasoning
The Authority determined that CKCL qualifies as a **Governmental Authority** as it is a government-owned company entrusted with municipal functions under Article 243W of the Constitution. The services provided by the applicant constitute solid waste management, which is a function listed in the Twelfth Schedule to the Constitution. Consequently, the services fall squarely within the scope of **Entry 3B of Notification No. 13/2023 - Central Tax (Rate)**, which provides a nil rate of tax for such services provided to a Governmental Authority.
Provisions relied on
- Section 2(16) of the IGST Act, 2017
- Article 243W of the Constitution of India
- Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017
- Notification No. 13/2023-Central Tax (Rate) dated 19.10.2023
For the practitioner
This ruling confirms that private contractors providing solid waste management services to government-owned entities like CKCL can claim **GST exemption** under Entry 3B of Notification No. 13/2023. It provides clarity for practitioners by affirming that such entities qualify as Governmental Authorities when performing municipal functions. However, it does not address the taxability of services provided to non-governmental entities or services outside the scope of solid waste management.
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/8-tiffot-1.pdf
Legibility of the scan, as read: high.
Prepared 15-10-2026.
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