GST on EPC contract for establishment of Fluids Servicing System

In re Tata Projects Limited (GST AAR Tamilnadu)

Q1. Whether supply of Engineering, Procurement and Construction (EPC) contract for establishment of Fluids Servicing System where in both goods  and services are supplied can be construed to be a composite supply in terms of Section 2(30) of CGST Act, 2017.

The Supply of Engineering, Procurement and Construction (EPC) contract for establishment of Fluids Servicing System between the applicant and IPRC is a composite supply in terms of Section 2(30) of CGST and TNGST Act, 2017.

Q2. If Yes, Whether the Principal Supply in such case can be said to be “ Establishment of Fluids Servicing System(FSS)” can be taxable at 5% GST vide notification No.45/2017- Central Tax(Rate) dated 14/11/2017.

This supply is a works contract in terms of Section 2(119) of CGST and TNGST Act, 2017 and hence Notification No.45/2017- Central Tax(Rate) dated 14/11/2017 and corresponding SGST Notification vide G.O. (Ms) No.161, dated 14.11.2017 is not applicable

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