Case of Ramandeep Upkarsingh Bindra (Black Rock Crusher), AAR Maharashtra Ruling Dated 28th November 2025. AAR held that what the government supplies is a licensing service granting the right to explore, extract, and use minerals, not a transfer of the right to use pre-existing goods. Such services fall under SAC 997337 and are taxable at 18% GST. Since the service is supplied by the State Government to a business entity, GST is payable by the recipient under the reverse charge mechanism as per Notification No. 13/2017. Thus, the royalty paid forms part of the consideration for taxable licensing services, and the applicant is liable to discharge GST under RCM at 18%.
