Case of Odisha State Medical Corporation Limited, AAR Odisha Ruling Dated 10th July 2025. AAR has determined that the Odisha State Medical Corporation Limited (OSMCL) is not eligible for a GST exemption on its services to the state government. It states that while OSMCL qualifies as a ‘Government Entity’ in terms of explanation in Para 2(zfa) of Notification 12/2017 (Rate) dated 28th June 2017, the services it provides are not ‘pure services’, and therefore, do not meet the criteria for exemption under Notification 12/2017 (Rate).