Case of Food Corporation of India, AAR West Bengal Ruling Dated 27th February 2026. AAR analysed that for exemption under Serial No 3 of Notification 12/2017, three cumulative conditions must be satisfied i.e., (a) the service must be pure service (b) the service must be provided to the Central Government, State Government, Union Territory, or local authority and (c) the service must be in relation to functions entrusted under Articles 243G or 243W. FCI, being a Government Entity, does not fall within the specified categories of Central Government, State Government, Union Territory, or local authority. The exemption is not applicable for this service provided to FCI being a Government Entity.