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Microlesson · 5-min read

Exemption - Services by Government

# Exemption: Services by Government (CG/SG/UT/LA)

## Key Definitions

  • Government = CG or SG working through offices/departments. Regulatory/autonomous bodies (SEBI, RBI, FSSAI, IRDA, DGCA, CCI) are NOT Government.
  • Government Authority/Entity = Body in which Government has ≥ 90% participation by equity or control, and
  • Set up by an Act of Parliament/State Legislature, or
  • Established by any Government.
  • Local Authority = Panchayat, Municipality, Zila Parishad, District Board, Cantonment Board, Regional Council, District Council, Development Board.
  • Excludes local development authorities like DDA, JDA (treated as Government Authority, not Local Authority).

## Part I — Always-Exempt Government Services

1. Activities entrusted to a panchayat (Art. 243G) or municipality (Art. 243W) by a Government Authority — e.g., sanitation, gardens, statutory collections by RERA.

2. Service by Government Entity to CG/SG/UT/LA or nominated person where consideration is in the form of grants.

3. Loan guarantee by CG/SG/UT to its PSU borrowing from banks/FIs.

4. Officers deputed by Government after office hours for cargo handling of import/export (merchant overtime charges).

5. Old age homes run by CG/SG or a 12AA/AB-registered entity — for residents aged ≥60, charging up to ₹25,000/month/member.

6. Department of Posts — post card, inland letter, book post, and ordinary post weighing < 10 grams.

7. Rehabilitation professional providing therapy/counselling at medical establishments, educational institutions, or rehabilitation centres set up by CG/SG/UT or 12AA/AB trust.

8. CG/SG/UT/LA services for: registration required by law; testing/calibration/certification for safety (e.g., fire licence); issue of passport, visa, DL, birth/death certificates; tolerating non-performance of contract (fines/liquidated damages); assignment of natural resource rights to a farmer for agriculture (except rearing horses).

9. Indian Railways to individuals: platform tickets, retiring/waiting rooms, cloak rooms, battery-operated car services.

10. Inter-zonal / inter-divisional services within Ministry of Railways.

11. R&D services against grants by Government Entity or by research bodies notified u/s 35 of Income-tax Act (notification must subsist at time of supply).

12. State Government → ERCC (excess royalty collector contractor): assigning royalty collection rights from mining lease holders.

  • If GST deposited by mining lease holder < exempted amount, ERCC pays the differential.

## Part II — Other Government Services (Conditional)

Three services are always Taxable, regardless of recipient:

  • (a) Services by Department of Posts and Ministry of Railways (other than the carve-outs in Part I)
  • (b) Transport of goods or passengers
  • (c) Services to an aircraft or vessel, inside or outside the port

For all OTHER Government services:

```

Recipient is non-business person -> Exempt

Recipient is CG/SG/UT/LA -> Exempt

Recipient is business entity:

  • Turnover <= threshold -> Exempt EXCEPT renting of immovable property (always taxable)
  • Turnover > threshold:
  • Consideration <= 5,000 (5,000/year if continuous) -> Exempt
  • Consideration > 5,000 -> Taxable (under RCM)

```

Worked example

### Example 1

Q. RERA collects statutory fees from real-estate developers.

A. RERA is a Government Authority; collection is for functions entrusted under Art. 243W → Exempt.

### Example 2

Q. Mr. Ram pays ₹15,000 to Rajasthan Government for registration of his vehicle.

A. Registration required under any law → Exempt.

### Example 3

Q. Government of Rajasthan grants ERCC rights to Mr. Shiva; exempted GST limit on royalty = ₹2 crore; mining lease holder deposits only ₹1.5 crore.

A. Differential of ₹50 lakh must be paid by Mr. Shiva (ERCC) to the Government.

### Example 4

Q. Central Government provides general insurance directly to school students; premium paid by parents.

A. Recipients are non-business persons; service is not transport/posts/aircraft → Exempt.

### Example 5

Q. SG provides a service to a business entity (turnover > threshold) for ₹4,500 one-time consideration.

A. Consideration ≤ ₹5,000 → Exempt (provided service is not the three always-taxable items).

⚠️ Common exam mistakes

  • Treating SEBI/RBI/FSSAI services as 'Government' services — they are not Government for this exemption.
  • Applying the ₹5,000 small-value exemption to transport/posts/aircraft services — those are always taxable.
  • Exempting renting of immovable property by Government to a small business — renting is taxable even where turnover is below threshold.
  • Forgetting that DDA/JDA are Government Authorities, not Local Authorities.
  • Confusing ERCC mechanism — the ERCC pays the shortfall, not the mining lease holder.
Reference: — Notification No. 12/2017-CT(R)
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