Is Public Function Activity or Sovereign Based

J's Position for today. The ruling in AAR No. KER/29/2025 (Kerala Devaswom Recruitment Board) delivers a clear message: under GST, the character of an activity matters more than the character of the institution performing it. By treating recruitment examinations conducted by a statutory body as a taxable supply of services, the Authority has applied the expansive definitions of “supply” and “business” in the CGST Act to hold that examination fees constitute consideration, notwithstanding the absence of profit motive or the public nature of the function.