Authority for Advance Ruling, Karnataka ◆ 29 Jul 2026 Government Contractors
S.K. Swamy and Company, In re In favour of the revenue
S.K. Swamy and Company, a registered Karnataka partnership, sought an advance ruling (Order KAR.ADRG/42/2026, 29 July 2026) on whether its activity of supplying ballast and loading it into Railway wagons using JCB loaders constituted a works contract under GST. The Karnataka AAR (Members Rama Rao and Itagi) found no building, construction, erection, or work connected with immovable property; the engagement was essentially supply and loading of goods for rail transport. Accordingly the arrangement could not be classified as a works contract under the statutory definition in Section 2 CGST, with implications for tax treatment under Sections 8 and 9. Outcome favoured revenue’s view that works-contract classification was unavailable. Contractors performing similar loading-only services should analyse immovable-property nexus separately; this summary is not legal advice.
CGST S.2 CGST S.9 CGST S.8
