Digitalisation, GIS Mapping And Tech Consultancy For Jal Jeevan Mission Are 'Pure Services', Exempt From GST: West Bengal AAR
The West Bengal Authority for Advance Ruling (AAR) has held that digitalisation, GIS mapping, monitoring, data management and technical consultancy services provided to the Public Health Engineering Department (PHED) in connection with water supply schemes qualify as “pure services” and are exempt from Goods and Services Tax (GST) under Notification No. 12/2017. The...
The West Bengal Authority for Advance Ruling (AAR) has held that digitalisation, GIS mapping, monitoring, data management and technical consultancy services provided to the Public Health Engineering Department (PHED) in connection with water supply schemes qualify as “pure services” and are exempt from Goods and Services Tax (GST) under Notification No. 12/2017.
The Authority ruled that such services are directly related to functions entrusted to Panchayats and Municipalities under Articles 243G and 243W of the Constitution, particularly those concerning drinking water and sanitation.
The ruling was delivered on an application filed by Rimita Mukherjee, an entity engaged in providing digitalisation, monitoring, GIS-based mapping, mobile and web application development, data analysis and technical consultancy services for piped water supply schemes implemented by the PHED under the Jal Jeevan Mission.
The applicant sought clarity on whether services such as digitisation of water supply schemes, enhancement of Jal Mitra applications, GIS-based asset mapping, monitoring dashboards, field data acquisition, and related consultancy would qualify for exemption as “pure services”.
The Authority examined the nature of the services and recorded that they involved no transfer of goods and were limited to service elements such as data collection, software development, GIS integration, analytics and reporting.
The Authority bench of Shafeeq S, Joint Commissioner, CGST & CX and Jaydip Kumar Chakrabarti, Senior Joint Commissioner, SGST observed that drinking water and sanitation are specifically listed in the Eleventh Schedule to the Constitution under Article 243G. It noted that PHED is a department of the Government of West Bengal and that the services were provided directly to the State Government.
The Authority held that the exemption notification requires satisfaction of four conditions: the service must be pure, must not involve goods, must be provided to the government or local authority, and must relate to constitutional functions under Articles 243G or 243W. It found that all four conditions were met in the present case.
The Advance Ruling Authority further clarified that even proposed or future services of a similar nature such as acquisition of field-level data, UTWID generation platforms, hosting of WhatsApp bots, and GIS-based monitoring tools, would also qualify for exemption, provided they remain service-only supplies.
Accordingly, the Authority ruled that the services are classifiable under Entry 3 of Notification No. 12/2017 and attract nil GST.
Case Title: Rimita Mukherjee
Case Number: WBAAR 15 of 2025-26
Date of Ruling: 09 December 2025
For Applicant: Mr. Rajkumar Banerjee, Advocate and Ms. Payel Agarwal, A/R