Tiffot Private Limited's Services to Clean Kerala Company Limited Recognized as Exempt from GST under Recent Notification
In a significant ruling, the Authority for Advance Rulings in Kerala has provided clarity on the GST applicability for solid waste management services, a critical municipal function. The ruling, dated October 10, 2025, pertains to Tiffot Private Limited, a company engaged in the collection, storage, transportation, processing, and bundling of non-recyclable plastic waste across various local government bodies in Kerala.
The applicant, Tiffot Private Limited, had sought an advance ruling to confirm whether their services to Clean Kerala Company Limited (CKCL), a government-owned entity, were exempt from GST under Entry 3B of Notification No. 13/2023 - Central Tax (Rate), dated October 19, 2023. CKCL, being wholly owned by the Government of Kerala, qualifies as a "Governmental Authority" under GST law.
The Authority, comprising Shri Jomy Jacob, IRS, and Shri Mansur M.I, examined the provisions under the Central Goods and Services Tax (CGST) Act and related notifications. They determined that the activities undertaken by Tiffot Private Limited fall under the category of "solid waste management," which is explicitly exempt from GST when provided to a Governmental Authority.
The ruling emphasized the legislative evolution and judicial precedents supporting the exemption of services related to municipal functions. The reinstatement of such exemptions by the 2023 notification underscores the government's intention to relieve essential civic services from GST burdens, which had been a point of contention after amendments in 2021.
This decision not only aligns with the constitutional mandates under Article 243W but also reinstates the exemption originally available under earlier GST notifications. The ruling is expected to provide much-needed relief and clarity to contractors and service providers engaged in essential public services across the country.
Bottom Line:
GST - Solid waste management services rendered to a Governmental Authority are exempt from GST under Entry 3B of Notification No. 13/2023 - Central Tax (Rate), dated 19th October 2023.
Statutory provision(s): CGST Act, 2017, Notification No. 13/2023 - Central Tax (Rate), Article 243W of the Constitution, Solid Waste Management Rules, 2016
Tiffot Private Limited, (AAR)(Kerala) : Law Finder Doc Id # 2835246
