Security & Scavenging Services To Govt Hospitals Qualify As "Pure Services", Exempt From GST: West Bengal AAR
The West Bengal Authority for Advance Ruling (AAR) has held that security and scavenging services provided to government-run medical colleges and hospitals qualify as “pure services” and are exempt from Goods and Services Tax (GST) under Notification No. 12/2017. The Authority held that services essential to the functioning of public hospitals, when supplied without any element...
The West Bengal Authority for Advance Ruling (AAR) has held that security and scavenging services provided to government-run medical colleges and hospitals qualify as “pure services” and are exempt from Goods and Services Tax (GST) under Notification No. 12/2017.
The Authority held that services essential to the functioning of public hospitals, when supplied without any element of goods, fall within activities relating to functions entrusted to Panchayats and Municipalities under Articles 243G and 243W of the Constitution.
An application was filed by Ex Servicemen Resettlement Society, which provides security personnel and scavenging staff on a contractual basis to various state-run medical colleges, district hospitals and sub-divisional hospitals in West Bengal. The applicant submitted that it raised monthly bills comprising only wages, employer's contribution to EPF and ESIC, and annual bonus, without supplying any goods.
The applicant sought a ruling on whether such services were exempt from GST as “pure services” under Entry 3 of Notification No. 12/2017, which grants exemption to services provided to the government or local authorities in relation to functions entrusted under Articles 243G and 243W.
The Authority examined the scope of “pure services” and noted that the term excludes works contracts or composite supplies involving goods. It recorded that the invoices produced showed no supply of goods and were restricted solely to labour-related components.
The Authority further observed that public health, sanitation, conservancy and hospital services are expressly listed under the Eleventh and Twelfth Schedules to the Constitution. It held that security and scavenging services are indispensable support services without which hospitals cannot function effectively.
The Authority stated that the expression “any activity in relation to” used in the exemption notification has a wide ambit, and that essential support services enabling delivery of public health services clearly fall within its scope.
Answering the question in the affirmative, the Authority ruled that the services provided by the applicant satisfy all three conditions under Entry 3 of Notification No. 12/2017 and are therefore exempt from GST.
Case Title: Ex Servicemen Resettlement Society
Case Number: WBAAR 22 of 2025-26
Date of Ruling: 10 December 2025
For Applicant: Mr. Sunirmal Basu, Vice president of applicant